New England Interstate
Water Pollution Control
Commission

www.neiwpcc.org/lustline
116 John Street
Lowell, Massachusetts
01852-1124
LU.S.T.L
A Report On Federal & State Programs To Control Leaking Underground Storage Tanks
Bulletin 66
December
2O1O
                          er  d^&rses  f
USEPA's  Partial  El 5 Waiver
Still Has Some Its, Ands, or Buts
by Patricia Ellis


Prologue
One of the goals of the Energy Policy Act of 2005 (EPAct 2005)
was to expand the use of renewable fuels in the transportation
sector. This legislation required the establishment of a Renew-
able Fuels Standard (RFS). In December 2007, Congress passed
the Energy Independence and Security Act of 2007 (EISA), which
revised the RFS, and, in effect, greatly increased the volumes of
renewable fuels required. EISA required that 15.2 billion gallons
of renewable fuel be used in the transportation sector in 2012,
and at least 36 billion gallons per year by 2022. (See page 6.)
   Current USEPA regulations allow a maximum of 10 percent
ethanol, by volume, to be blended into gasoline. The total quan-
tity of ethanol being  blended into gasoline today is nearing 10
percent of the volume of gasoline consumption, which means
that ethanol is about to hit its upper limit, or "blend wall." There
are two ways we can  use ethanol to meet the renewable fuel tar-
gets set by EISA: either we have to use more E85 (which can
only legally be used in flex-fuel vehicles), or we need to be using
more than 10 percent, by volume, of ethanol in conventional and
reformulated fuels.
   On October 13,2010, USEPA granted a partial waiver for the
use of gasoline containing up to 15 percent by volume ethanol
(Federal Register: Nov.  4, 2010, Vol. 75, No. 213). The waiver
applies only to model year 2007 and newer light-duty motor
vehicles,  which includes passenger cars, light-duty trucks, and
medium-duty passenger vehicles. A decision on the use of E15
in vehicle model years  2001 through 2006 will be made after
USEPA reviews the results of additional testing by the Depart-
ment  of Energy, which  was recently completed. (See  "NREL's
Study on Testing Mid-Level Ethanol/Gasoline in Dispensing
Equipment" on page 7.)
   No waiver is being granted for the use ofE15 in model year
2000  and older cars and light trucks or in any motorcycles,
                      heavy-duty vehicles, or non-road engines, because currently
                      there is no testing data to support such a waiver. You can find
                      all documents relating to the Waiver Request at http://www.epa.
                      gov/otaq/regs/fuels/additive/e157. During the comment period on
                      the waiver request about 78,000 comments were submitted to
                      the USEPA docket. Only a handful of these comments mentioned
                      UST-system infrastructure issues.
                                                    I continued on page 2
                                        Inside
                           NREL Study—Mid-Level Ethanol in Dispensing Equipment

                           It's the Compatibility Thing—Iowa

                           Ferreting Out the Identity of Gasoline Additives

                           Predicting Impact of Biofuels on BTEX Plumes

                           Vapor Intrusion: Petroleum Hydrocarbon Issues

                           In Situ Chemical Oxidation

                           National LUST Cleanup Backlog

                           New ASTM Release Investigation Standard

                           Class C Operator Saves the Day

                           RP100 UST Installation Document

                           FAQs: Unsupported Leak Detection Methods

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LUSTLine Bulletin 66 • December 2010
• Partial E15 Waiver from page 1
    Because of the confusing nature of
all of this, USEPA is taking several steps
to help consumers easily identify the
correct fuel for their vehicles and equip-
ment.  First, the agency is proposing
pump-labeling  requirements, including a
requirement that the fuel industry specify
the ethanol content of gasoline sold to
retailers. There would also be a quarterly
survey of retail stations in  most areas
across the country. The proposed rule is a
"Regulation to  Mitigate the Misfueling of
Vehicles and Engines  with Gasoline Con-
taining Greater than Ten Percent Ethanol
and Modifications to the Reformulated
and Conventional Gasoline  Programs,"
which has a comment period that ends on
January 3,2011.

The API Report
With  the granting of the partial
waiver request, many changes will
have to be made in rules and regula-
tions before E15 can be sold legally.
An August 2010 report, Identification
and Review of State/Federal Legislative
and Regulatory Changes Required for
the Introduction of New Transporta-
          L.U.S.T.Line

        -*  EUen Frye, Editor
          Ricki Pappo, Layout
     Marcel Moreau, Technical Adviser
    Patricia Ellis, PhD, Technical Adviser
 Ronald Poltak, NEIWPCC Executive Director
    Deb Steckley, USEPA Project Officer
 LUSTLine is a product of the New England
 Interstate Water Pollution Control Commis-
  sion (NEIWPCC). It is produced through
 cooperative agreements (US-83384301 and
 US-83384401) between NEIWPCC and the
   U.S. Environmental Protection Agency.
   LUSTLine is issued as a communication
      service for the Subtitle I RCRA
   Hazardous & Solid Waste Amendments
        rule promulgation process.
     LUSTLine is produced to promote
 information exchange on UST/ LUST issues.
 The opinions and information stated herein
  are those of the authors and do not neces-
   sarily reflect the opinions of NEIWPCC.
     This publication may be copied.
     Please give credit to NEIWPCC.
   NEIWPCC was established by an Act of
   Congress in 1947 and remains the old-
  est agency in the Northeast United States
 concerned with coordination of the multi-
      media environmental activities
    of the states of Connecticut, Maine,
     Massachusetts, New Hampshire,
   New York, Rhode Island, and Vermont.

             NEIWPCC
            116 John Street
         LoweU, MA 01852-1124
        Telephone: (978) 323-7929
          Fax: (978) 323-7919
         lustline@neiwpcc.org
    *® LUSTLine is printed on recycled paper.
                           New Transportation Fuel Identified
                                    Infrastructure/ Dispenser
                                     Testing Development
                                    EPA Waiver/Substantially
                                     Similar Determination
                                   Modify ASTM/NIST Specs
                          Modify State Fuel
                           Requirements
                    Modify Codes/
                      Develop
                    Infrastructure
                         Finalize Distribution
                          Implementation
FIGURE 1. Generic schematic of the process for introduction of new transportation fuels.
tion Fuels, prepared for the Ameri-
can Petroleum Institute by  Sierra
Research, Inc., details what needs
to be done before E15 can be intro-
duced into the marketplace (http://
www.api.org/aboutoilgas/otherfuels/
upload/Sierra_Final_Alt_Trans_Fuel_
Report_0804W.pdf).
    The introduction of a new trans-
portation fuel into  the marketplace
is not simple or straightforward; it
requires numerous changes to fed-
eral and state laws, regulations, and
standards. The time required to make
all of the required changes listed by
Sierra is estimated to be as much
as several years. Figure 1  shows a
generic  schematic  of the required
process, along with estimated time
frames needed to complete  the vari-
ous tasks. At the time that the partial
waiver was announced, some news
articles claimed that E15 would be
available for sale as soon as a few
months from now.  Evidently a few
states plan on skipping a few steps in
the process!
    The API  report  includes an
appendix summarizing the antici-
pated changes that will be required
for each state in order to introduce
ethanol blends greater than 10 per-
cent into commerce. In this article,
I will attempt to  provide some
essential hurdles discussed in this
report—federal requirements, state
requirements, warranties, fuel stor-
age, marketing and distribution, and
liabilities.

Federal Fuels Requirements
•  New  Transportation Fuels  Must
be "Substantially Similar"  to Existing
Fuels  Since E15 contains  more than
2.7 percent oxygen, by weight, it
does not qualify to be "substantially
similar"  to existing fuels; therefore a
waiver must be issued before it can
be used as a transportation fuel.

•  Fuel  Registration  and  Health
Effects  Part 79 of the Title 40 Code
of Federal Regulations requires that
any manufacturer of a motor-vehicle
gasoline or  diesel fuel or an additive
used in  either, must register  with
USEPA prior to introduction of the
fuel or additive into commerce. A
rule was later added requiring health
effects information  and additional
air-related  research. In addition  to
basic registration information about
product  composition, concentration,
and production volume, information
must be provided about combus-
tion emissions,  evaporative emis-
sions, and potential adverse health
effects related to inhalation of these
emissions. The health-effects testing
usually  involves exposing labora-
tory test animals to the emissions.
USEPA evaluates the results of these

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                                                                              December 2010 • LUSTLine Bulletin 66
submissions and makes a determina-
tion as to whether additional testing
is required. Only when all testing has
been submitted  and evaluated by
USEPA can the fuel or fuel additive
be registered and introduced into
commerce.

•  Fuel Rating and Labeling   Since
USEPA issued a "partial waiver,"
allowing blends with ethanol greater
than 10 percent  only in vehicles
newer than a specific model year,
additional labeling  requirements
may be necessary, either by the FTC
or USEPA. If more aggressive means
than pump labeling  are required
to prevent misfueling with higher-
level ethanol blends, implementation
could take several years and could
be quite costly. The announcement of
proposed rulemaking was issued the
same day that the partial waiver was
granted.
   The Federal Trade Commission
(FTC) administers requirements for
gasoline and diesel-fuel ratings and
labeling. Existing regulations  cover
ethanol blends up to E10 and fuels
with at least 70 percent ethanol, but
blends between E10 and E70 are not
currently covered. The FTC has initi-
ated a rulemaking for blends greater
than E10, which would require  either
identification of the precise  concen-
tration of ethanol in  the blend  or
disclosure of the range of ethanol in
the blend. In addition, the proposal
would change labeling requirements
for  all gasoline-ethanol blends  to
warn that blends with more than  10
percent ethanol may harm some con-
ventional vehicles. Since both  agen-
cies are simultaneously proposing
rules for the same thing, let's hope
their efforts will be collaborative.

•  Gasoline Detergent Certifica-
tion  The Clean Air Act mandated
that USEPA adopt regulations requir-
ing  the use of additives in gasoline
to prevent the buildup of deposits
in engines or fuel-supply systems.
Since existing certifications  were
made using fuels containing no more
than 10 percent ethanol, changes  to
USEPA gasoline detergency regula-
tions  with ethanol blends  greater
than 10 percent will need to be  made
to assure that additives are effective
in preventing buildup  in engines
using  blends with more than 10 per-
cent ethanol.
•  Volatility Exemption for Ethanol
Blends Greater Than 10 Percent  The
addition of ethanol to a gasoline
blendstock increases the volatility
of the blend relative to neat gaso-
line; therefore, USEPA created a one-
psi exemption for gasoline-ethanol
blends sold in the summer months
in non-reformulated gas (RFG) areas.
The exemption does not apply to
gasoline with  greater than 10 per-
cent ethanol. Without an exemption,
a lower-volatility blendstock would
need to be used. A USEPA rulemak-
ing to extend the exemption to higher
ethanol concentrations could take six
to twelve months. The federal Reid
vapor pressure (RVP) exemption is
not an issue in RFG areas, because
the same VOC requirements would
apply for blends with more than
10 percent ethanol as for other RFG
blends, including E10.
   The USEPA partial waiver deci-
sion document includes a discus-
sion by USEPA that it is believed
that E15 blends with higher vola-
tility  would cause vehicles  to vio-
late their evaporative  emissions
standards. Therefore, the partial
waiver is for E15 blends  that meet
the summertime gasoline volatility
standards for conventional gasoline
without any 1.0 psi RVP waiver. In
order to  introduce a fuel that both
meets the federal summertime RVP
standards and contains between 10
and 15 percent ethanol, fuel refiners
would have to create a fuel or blend-
stock  that has approximately 1.0 psi
lower RVP than a fuel or blendstock
intended for E10 due to the interac-
tion between gasoline volatility and
ethanol when blended.

•  RFG   Federal RFG requirements
are still in effect along most of the
northern Atlantic  seaboard, most
of California,  and in  a number of
other  major urban areas. A Complex
Model is used to determine where
RFG is required. The Model esti-
mates the impacts of changes in eight
specific gasoline properties relative
to a 1990 baseline. The  proposed
rule includes changing the Complex
Model for  ethanol blends greater
than E10, because the limit for oxy-
gen content in the Model was 4.0
percent by weight (approximately
Ell.5). The length of time required to
revise these regulations will depend
on  whether sufficient  emissions
data exists for vehicles representa-
tive of 2007 vehicle fleets. EPAct 2005
required some of this testing.

State  Fuels Requirements
In addition to the federal fuel
requirements, most states and some
regions have enacted  their own
requirements for transportation
fuels.

•  ASTM and  NIST Specifications
Many states have adopted Ameri-
can Society for Testing and Mate-
rials (ASTM)  specifications for
gasoline (ASTM D4814) or specifica-
tions established by National Con-
ference on Weights and Measures
(NCWM) under the National Insti-
tute of Standards and Technology
(NIST). While the scope of the ASTM
standard applies to ethanol blends
greater than E10, it is unlikely that
ethanol blends greater than 10 per-
cent could meet the T50 limits of the
current version of the standard with-
out modification (the T50 limit is
the temperature at which 50% of the
gasoline would  evaporate). The cur-
rent lower T50 limit applies only to
ethanol blends from 1 to 10 percent
by volume. Most states have adopted
some version of the ASTM standard,
but some adopt the most recent ver-
sion and others adopted the version
of a  specific year. Some states have
adopted the NIST volatility limits for
ethanol blends, and similar problems
will exist for those states.

•  Blending Restrictions and Blending
Caps  Various states have  specified
a blending cap of 10 percent ethanol,
by volume, in state fuel specifica-
tions, state biofuels mandates, and
tax incentives for renewable fuels.
Other states have adopted the most
recent  version  of NIST Handbook
130,  which specifies a blending cap
of 10 percent. These states would
require either a change in state leg-
islation or regulations to permit
ethanol concentrations greater than
10 percent, or a modification by
National Conference on Weights and
Measures to the NIST handbook to
raise the blending cap.

•  Waivers from Gasoline Vapor-Pres-
sure Requirements   In addition  to
the federal RVP exemption for E10,
many states have adopted gasoline

                • continued on page 4

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LUSTLine Bulletin 66 • December 2010
• Partial E15 Waiver from page 3

volatility limits, either by adopting
ASTM D4814 or NIST Handbook
130, or by establishing state vapor-
pressure limits. A large number of
states would have to make changes
to expand RVP waivers to ethanol
blends greater than 10 percent.

•  T50 Minimum Offsets and Vapor-
Lock Protection (T@V/L=20)  Many
states have adopted their own allow-
ances for offsets for T50 minimum
distillation temperatures and vapor-
lock protection either by  adopting
ASTM D4814 or NIST Handbook 130,
or by independently establishing lim-
its through legislation and/or regu-
lation. Where their allowances are
limited to E10 blends, changes would
have to be made to apply them to eth-
anol blends greater than 10 percent.

•  California  To introduce  any
new fuel in California, a multimedia
assessment must first be conducted.
The second step involves the estab-
lishment of fuel specifications by
the California Air  Resources Board
to ensure that the new fuel  does
not result in increases in air pollut-
ant emissions.  In addition, all fuel
must comply with the California Air
Resources Board's (CARB's) Phase
3 RFC regulations, which currently
include a blend cap of 10 percent etha-
nol. The California Predictive Model
(similar in concept to the USEPA Com-
plex Model) must be used to analyze
data from an extensive vehicle-testing
program. The predictive Model indi-
cates increases in NOx emissions with
higher levels of ethanol,  therefore
other changes would have to be made
to the RFG 3 requirements to mitigate
this increase, such as further restric-
tions on sulfur content.

•  State Implementation Plans   For
states that are ozone non-attainment
areas, introducing ethanol blends
greater than 10 percent may require
changes to state implementation
plans under the Clean Air Act. If
changes are necessary, they require
USEPA approval.

Vehicle and Engine
Warranties
•  Light-Duty Gasoline Vehicles   Use
of ethanol blends greater than 10 per-
cent in light-duty gasoline vehicles
may void vehicle warranties, creat-
ing potential liabilities for vehicle
owners. A review of owner's manu-
als for ethanol usage in non-flex-fuel
vehicles for model years 1999, 2000,
2003, 2006, 2009, and 2010 shows that
10 percent ethanol is the maximum
concentration allowed by any manu-
facturer. Manufacturers may take the
position that they are not required
to address adverse impacts caused
by the use of higher blends of etha-
nol in existing vehicles that are in the
model years covered by the waiver.

• Other Gasoline-Fueled Equipment
Non-road products  with gasoline
engines include lawn mowers, chain-
saws, forklifts, boats, personal water-
craft, and all-terrain vehicles. USEPA
did not approve the Growth Energy
waiver request for non-road engines,
vehicles, and equipment for two pri-
mary reasons: (1) Growth Energy did
not provide enough information to
assess the potential impacts of E15 on
the compliance of non-road engines
with applicable emission standards,
and (2) concerns expressed by non-
automotive engine manufacturers
such as ALLSAFE (Alliance for a Safe
Fuels Environment). These concerns
include  the following: (1) engine
operability problems, including loss
of power, stalling, and overheating;
(2) substantially shortened engine life
due to enleanment of air-fuel ratios;
(3) catastrophic engine failures; (4)
incompatibility with fuel-system
materials; and (5) increases in exhaust
and evaporative emission levels.

Fuel Storage,  Marketing, and
Distribution
It is possible that many extensive,
time-consuming, and costly changes
may also be needed in the areas of
storing,  marketing, and distribut-
ing ethanol blends greater than 10
percent.  Numerous standards exist
regarding the installation and opera-
tion of  the fueling infrastructure.
Most of  these standards require that
the equipment be "compatible" with
the product being stored and dis-
pensed  and that the equipment be
"listed" by independent organiza-
tions such as Underwriters Laborato-
ries (UL).
    Organizations and regulatory
agencies with jurisdiction over or
standards that apply to  fuel-dis-
pensing facilities include the follow-
ing: Occupational Safety and Health
Administration (OSHA), National
Fire Protection Association (NFPA),
International Code Council (ICC),
UL, USEPA, and American National
Standards Institute. Many states also
have regulatory agencies with juris-
diction over fueling facilities and
fuel-dispenser and product labeling.

•  Pipelines and  Terminals  If E10
and ethanol blends greater than 10
percent use the same blendstocks,
minimal changes are expected with
regard to transportation and storage
infrastructure. With a partial waiver,
the amount of change that may be
required will depend on whether dif-
ferent blendstocks are required. Dif-
ferent blendstocks would need to be
transported separately and stored
separately at terminals.  Currently,
most ethanol is transported by barge,
rail, and truck, separately from gaso-
line. As larger and larger volumes
of ethanol are transported, pipelines
will become more attractive for etha-
nol and gasoline-ethanol blend trans-
port. This generates concerns over
water entrainment and phase separa-
tion of gasoline and ethanol; degra-
dation of materials used in pipelines
and storage tanks by  ethanol and
gasoline-ethanol blends; and stress
corrosion cracking of pipelines.

•  Retail  Fuel  Outlets   The main
concerns with respect to increasing
ethanol concentrations in gasoline
are similar to those for existing vehi-
cles—materials compatibility  with
components of the fuel storage and
dispensing systems. These concerns
raise liability issues for fueling out-
lets, and the marketing  of ethanol
blends greater than 10 percent could
be a violation of some local building
or fire codes. As the API report men-
tions, the following equipment may
need to be replaced or modified to
accommodate ethanol blends greater
than 10 percent:
•  Handling hardware (nozzles,
   hoses, breakaways, and swivels)
•  Dispensers
•  Product pumps
•  Underground storage tanks
•  Leak detection systems
•  Vapor-recovery systems
•  All associated piping

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                                                                             December 2010 • LUSTLine Bulletin 66
    Research is currently  under-
way on E15 retail infrastructure.
(See NREL study on page 7.) Three
million dollars is being spent on
infrastructure compatibility  testing,
including work underway by:
• U.S. Department of Energy
  - National Renewable  Energy
     Laboratory: Dispensers, piping,
     Stage II equipment, STPs
  - Oak Ridge National Labora-
     tory: Component  materials,
     UST coupons
• USEPA Office of Underground
  Storage Tanks  and  Office of
  Research and Development
  - Leak detection systems

• American Petroleum Institute
  - Misfueling mitigation measures
  - Flame arresters
  - Stage I Recovery Equipment
    All national fire codes  specify
that gasoline dispensers and associ-
ated dispensing equipment must be
"listed" by a nationally recognized
third-party testing laboratory, the
most well known being Underwrit-
ers  Laboratories. In terms of current
UL  dispenser and hanging hardware
listings, UL says "dispensing sys-
tems and hanging hardware have
been certified by UL for use with E15
and higher blends of ethanol. Leg-
acy dispensers, the  type presently
installed in most stations, have been
tested and certified for a maximum
blend of E10 only."
    The problem for tank  owners
who want to dispense E15 is that
they may have to replace perfectly
good legacy (E10) equipment for dis-
pensers that UL approves for  E15.
    So the larger problem lies with
existing equipment, which  has not
been evaluated with respect to E15,
and UL does  not list equipment
without required testing. UL says it
is up to the authority having juris-
diction to determine how to proceed.
In February 2009, UL announced its
support for authorities having juris-
diction (AHJ) who may chose to per-
mit legacy systems with UL approval
for  E10 to be used to dispense fuel
blends up to a maximum of 15 per-
cent ethanol.
    They stated that there didn't
seem to be any significant increase in
risk between E10 and E15 blends but
recommended that the AHJs consult
1910
       1920
with the equip-
ment manufac-
turers to confirm
that the  equip-
ment is compat-
ible with the fuel
to be stored. UL
recommended
that the dispens-
ers be subject to
regular inspec-
tion and main-
tenance because
the potential for
degradation of
the  metals and
other  materi-
als increases with increasing ethanol
concentrations. (What, no increased
risk, but increased chance of equip-
ment degradation?)
   Some states have issued work-
arounds that allow the use of legacy
and  newer dispensers,  mostly by
requiring periodic inspection and
replacement of the unlisted equip-
ment with listed equipment as soon
it becomes  available. These work-
arounds do not, however, exempt
retailers from federal OSHA require-
ments  for listed dispenser equip-
ment. Also,  it is unclear whether the
UL announcement applied only to
the dispenser itself or to all above-
ground dispensing  equipment,
including hanging hardware, break-
aways, and  so on. The UL announce-
ment and the state workarounds do
not address  the liability issues.

•  Changes  in Pump Labeling   State
advertising and labeling require-
ments may  require modification to
accommodate ethanol blends greater
than 10 percent, although many state
regulations  only require the posting
of labels alerting consumers to the
fact that the fuel contains ethanol.
Other state labels include the  per-
centage, or maximum percentage,
of ethanol in the fuel. In those cases,
the introduction of ethanol blends
greater than 10 percent will require
replacement or multiple replace-
ments  of pump labels, depending
on how new transportation fuels are
introduced.
   As discussed above, USEPA has
issued a Notice of Proposed Rule-
making to minimize the chances of
misfueling vehicles. One of the parts
of this rule would address dispenser
labeling. Such a label consists of four
Evolution of Fuel Additives
         petrofg
                      1970
                              2000
                                      2030
              components. The information com-
              ponent of the label would inform
              the consumer of the maximum etha-
              nol content that the fuel may con-
              tain. The legal approval component
              of the label would inform consum-
              ers of which vehicles and engines
              are approved to use E15. The techni-
              cal warning component of the label
              would alert consumers that the use
              of E15 in other  vehicles, engines,
              and equipment might cause damage
              to these products. The legal warn-
              ing component of the label would
              inform consumers that using E15 in
              a vehicle or engine not approved for
              E15 use violates federal law.
                  If USEPA extends the waiver to
              include vehicles made between 2001
              and 2006, the label would change
              accordingly. The 2007 and later vehi-
              cles represent about 20 percent of the
              current fleet of passenger cars and
              light-duty trucks, or about 42 million
              vehicles.
                  Scott Merritt,  executive direc-
              tor of the Nebraska Corn Growers
              Association, cautioned that a warn-
              ing label for E15 would be the wrong
              approach. "It will not be positive to
              retail sales. We have had discussions
              with retailers, and they are reluctant
              to put warning labels on pumps.
              From a consumer standpoint, it
              sends  a bad message. Consumer
              confidence is high on ethanol (in
              Nebraska). Consumers can't be very
              positive about a warning label—it
              sets us back 15 years." (DTN Progres-
              sive Farmer, Oct. 15, 2010.)

              A Real Predicament for Tank
              Owners!
              You have  to wonder  how many
              retail UST facility owners are going
                              • continued on page 6

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LUSTLine Bulletin 66 • December 2010
• Partial E15 Waiver from page 5

to want to mess with ethanol blends
greater than 10 percent. Chevron
has  already informed their mar-
keters that they are forbidden to
market E15, unless expressly autho-
rized.  The National Association of
Convenience Stores,  in  a release
issued shortly after the USEPA par-
tial waiver announcement, urged
its members to use extreme caution
when considering selling E15, stating
that the USEPA approval does noth-
ing to remove retailers' legal obliga-
tions regarding storage and sale of
the fuel. "Further, limiting E15 use
to only vehicles manufactured since
2007 could expose retailers to signifi-
cant  liability risk if a consumer were
to fill a non-approved engine with
E15," stated John Eichberger, NACS
vice  president of government rela-
tions (http://iviviv.ethanolproducer.com,
October 19, 2010).
   USEPA  stated in  its proposed
E15 label rule that it would not typi-
cally hold a fuel retailer liable for
consumer misfueling into  a non-
approved engine,  provided that
a station's  pumps  were properly
labeled. NACS claims that the Clean
Air Act includes a  provision that
allows for citizens to  sue retailers
for misfuelings, and that the labels
do not provide them  with enough
litigation protection. Valero Energy
Corporation is expanding E85 avail-
ability at many of its retail stations,
but Bill Day, corporate communi-
cations director, indicated that the
company  will not be as supportive
of E15. "Valero is one of the nation's
leading ethanol producers, and gen-
erally supports pro-ethanol poli-
cies," he said. "But in  this case, it's
hard to imagine any retailer, includ-
ing Valero, selling the E15 blend at
its sites without liability or warranty
protection."
   Representative Ross from Arkan-
sas and Representative Shimkus
from Illinois introduced H.R. 5778,
the Renewable Fuels Marketing
Act of 2010  in July 2010. One of the
provisions of this legislation would
require the USEPA Administrator,
within one  year  of  passage of the
bill, to issue guidelines for determin-
ing whether USTs and associated
dispensing  equipment are compat-
ible with  any fuel or  fuel additive
authorized by the Administrator or
by statute for use in a motor vehicle,
non-road vehicle, or engine.
    An additional  provision  of
the legislation attempts to allevi-
ate liability issues stemming from
the introduction of higher  ethanol
blends. It requires that the USEPA
Administrator issue regulations for
labeling within one year that prevent
the introduction and  transportation
of fuel into an engine that is not com-
patible with the fuel, and if the seller
complies with the labeling require-
ments, they will not be liable under
the provisions of this act or any other
provision of federal or state law for
"(1) a self-service purchaser's intro-
duction of such a transportation fuel
into a motor vehicle, non-road vehi-
cle, or engine that is not compatible
with such transportation fuel; or (2)
the voiding of the manufacturer's
warranty of such vehicle or engine
from the introduction of such a trans-
portation fuel."
    On October 21, Secretary of Agri-
culture Tom Vilsack announced that
the U.S. Department  of Agriculture
would use existing funds to assist
in the  installation of 10,000  blender
pumps across  the U.S. within the
next five years (less than 5  percent
of gas stations in the country). He
sees USEPA's approval for  E15 use
in vehicle models 2007 and newer as
a "momentum builder" for the etha-
nol industry, and it should help boost
demand for ethanol. He urged USEPA
to approve E15 for vehicle model
years 2001 to 2006 as soon as possible.
    "It's already convinced NASCAR
to use E15, and if it's good  enough
for Jimmie Johnson, I remain hopeful
that it will also be good enough for
earlier model vehicles," Vilsack said.
In response to the reluctance of retail
station owners to invest in additional
dispensers and storage tanks for E15,
Vilsack  has instructed rural devel-
opment officials to provide match-
ing funds for installing the blender
pumps. He was unable to provide an
exact cost for the initiative, but said
the agency has estimated that a com-
plete blender-pump system ranges in
price from $25,000 to $50,000, and that
work on the blender-pump program
will commence "immediately" (http://
www.ethanolproducer.com. October 21,
2010).
    Hmmmmmm.... So which UL-
approved  blender pumps will be
installed? And testing hasn't begun
yet on the functionality of leak detec-
tion systems for use with ethanol
blends.  I continue  to hope that we
have learned from  our past experi-
ence with MtBE that changes in our
fuel composition have to be done
carefully and our  decisions need
to include evaluation of all of the
potential pitfalls, including compat-
ibility with our existing fuel distribu-
tion system. •

  Pat Ellis, Ph.D., is a hydrologist with
  the Delaware Department of Natural
 Resources and Environmental Control,
  Tank Management Branch. She writes
   the LUSTLine column "Wander-
     LUST," and can be reached at
      Patricia.Ellis@state. de.us.
 USEPA Finalizes 2011  Renewable Fuel Standards
 USEPA has finalized the 2011  percentage standards for the four categories of fuel
 under the agency's renewable  fuel standard program, known  as RFS2. The Energy
 Independence and Security Act (EISA) amended the Clean Air Act to greatly increase
 the total required volume of renewable fuels each year, reaching a level of 36 billion
 gallons in 2022. To achieve these volumes, USEPA calculates percentage-based stan-
 dards for the following year. Based on the standards, each producer and importer of
 gasoline and diesel determines the minimum volume of renewable fuel that it must
 ensure is used in its transportation fuel.
   The final 2011 overall volume and standards are:
 •  Cellulosic biofuel: 6.6 million gallons; 0.003 percent
 •  Biomass-based diesel: 800 million gallons; 0.69 percent
 •  Advanced biofuel: 1.35 billion gallons; 0.78 percent
 •  Renewable fuel: 13.95 billion gallons; 8.01 percent
 Based on an analysis of expected market availability, USEPA is finalizing a lower 2011
 cellulosic volume than the statutory target. Overall, USEPA remains optimistic that the
 commercial availability of cellulosic biofuel will continue to grow in the years ahead.
 For more information, go to: http://www.epa.gov/otaq/fuels/renewablefuels/regula-
 tions.htm, •

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                                                                        December 2010 • LUSTLine Bulletin 66
             USEPA Proposed Guidance on Compatibility of UST Systems
                           with Biofuel Blends Is Now Available
  In the November 17, 2010 Federal Register (http://www.gpo.gov/fdsys/pkg/FR-2010-11-17/pdf/2010-28968.pdf), USEPA
  published proposed guidance that will clarify how underground storage tank owners and operators can comply with the
  Agency's compatibility requirement (in 40 CFR §280.32) when storing certain biofuels, such as ethanol-blended fuels greater
  than 10 percent ethanol and biodiesel-blended fuels containing an amount of biodiesel to be determined.
  USEPA solicited comments (due on December 17, 2010) on the proposed guidance, which will provide underground storage
  tank owners and operators with greater clarity in demonstrating compatibility of their tank systems with these fuels.
  Contact Andrea Barbery (barbery.andrea@epa.gov) of USEPAs Office of Underground Storage Tanks for more information.
NREL's  Study on Testing  Mid-Level Ethanol/
Gasoline in Dispensing  Equipment Now Online
     The National Renewable Energy
     Laboratory's  (NREL) Non-
     petroleum-Based Fuel Task
is responsible for addressing the
hurdles to commercializing fuels
and fuel blends such as ethanol that
are derived from biomass. One such
hurdle is the unknown compatibility
of new fuels with legacy infrastruc-
ture components at fuel-dispensing
facilities.  The U.S. Department of
Energy's (DOE) Vehicle Technology
Program and the NREL biomass pro-
gram engaged in a joint project to
evaluate the potential for blending
ethanol into gasoline at levels higher
than El 0.
   The project, carried  out by
Underwriters  Laboratories  Inc.
(UL), was initiated to help DOE and
NREL [and, by the way, UST regula-
tors] better understand potentially
adverse impacts caused  by  any
dispensing equipment incompat-
ibility with ethanol blends higher
than equipment design  specs. UL's
November 2010  report, Dispens-
ing Equipment Testing with Mid-Level
Ethanol/Gasoline Test Fluid, provides
data on the impact of introducing
gasoline with a higher  volumetric
ethanol content  into dispensing
equipment from both a safety and a
performance perspective. Safety of
the equipment focuses  on  "loss of
fuel containment and other safety-
critical performance such as loss of
ability to stop fuel flow or failure of
breakaway couplings to separate at
appropriate forces."
   As detailed in the  report, the
project consisted of testing new and
used dispensers harvested from the
field (all  equipment UL-listed for
up to E10). Testing was performed
according to requirements in the
UL's Outline of Investigation for Power-
Operated Dispensing Devices for Gaso-
line and Gasoline/Ethanol Blends with
Nominal Ethanol Concentrations up
to 85 Percent (EO-E85), Subject 87A,
except using a CE17a test fluid based
on the scope of this program.
   As reported in the UL's execu-
tive summary, "the overall results of
the project were inconclusive insofar
as no clear trends in the overall per-
formance of all equipment could be
established. New and used equip-
ment such as shear valves, flow lim-
iters, submersible turbine  pumps,
and hoses generally performed well.
Some new and used equipment dem-
onstrated reduced levels of safety or
performance, or both, during either
long-term exposure or performance
tests. Dispenser meter/manifold/
valve assemblies in particular dem-
onstrated largely noncompliant
results. Nozzles, breakaways, and
swivels, both new and used, expe-
rienced noncompliant results dur-
ing performance testing. Responses
of nonmetals, primarily gaskets and
seals, were involved with these non-
compliances."
   The report summarizes the per-
formance of different types of equip-
ment in the testing program (Table
1). The report is available at: http://
www.nrel.gov/docs/fyllosti/49187.pdf.
Note: This report documents the
noncompliance (i.e., failure) of cer-
tain nonmetallic materials that may
be found in UST equipment. •
 TABLE 1.       SUMMARY OF TEST RESULTS ON DIFFERENT
                       TYPES OF EQUIPMENT
                    Compliant Test    Compliant Test        Overall
                    Results on New    Results on Used    Compliant Test
 Equipment             Samples3        Samples3         Results3
Breakaways
Flow Limiters
Hoses/Hose Assemblies
Meter/Manifold/Valve
Assemblies
Nozzles
Shear Valves
Submersible Turbine
Pumps
Swivelsb
2 of 5
1 Of1
8 of 9
Oof 2
3 of 6
3 of 3
1of1
3 of 4
1of4
-
4 of 6
Oof 4
1of4
-
_
3 of 5
3 of 9
1 Of1
12 of 15
Oof 6
4 of 10
3 of 3
1of1
6 of 9
a. In the context this table, "compliant results" is used to include fully compliant test results and inconclu-
sive test results that did not directly manifest a hazard, such as leakage, during the testing that was able to
be performed as a part of this research program.
b. Includes swivels integral to hose assemblies.

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LUSTLine Eullek
                   mber 2010
                  It's  the  Compatibility Thing
                  How  Two UST Regulators in the Land of Ethanol
                  Addressed Ethanol Compatibility
                  by Ellen Frye

         From the very beginning,
         we made sure we talked
         about compatibility, about
what we  are regulating, and  why,"
said Paul Nelson, Senior Environ-
mental Specialist with the Iowa
Department of Natural Resources
(DNR), in a recent interview with
Marcel  Moreau (author of the
LUSTLine column "Tank-nically
Speaking"). "We stayed away from
expressing opinions for or against
ethanol to avoid alienating  some-
body," Paul explained. "The regula-
tory issue is very straightforward.
It's about compatibility and prevent-
ing a release into the environment.
The federal rules, which Iowa has
adopted, say the UST-system compo-
nents have to be compatible with the
fuel being stored."
   But compatibility is not only
a fuels issue. As Marcel is  quick
to point out, both Paul and his co-
worker Tom Collins, Senior Environ-
mental Specialist, have a personal
style that is instinctively compatible
with their various stakeholders—
tank owners and operators, install-
ers, equipment manufacturers and
distributors, fuel associations, and
the state legislature. The two of them
are a team and have been an effec-
tive force in piloting the state's UST
program since the program began 20
years ago. Their strategy is decep-
tively simple: identify the issues,
research them, and present them to
stakeholders along with a reasonable
plan. A key component of the strat-
egy is to involve the  stakeholders
each step  of the way.
   Iowa is the number one etha-
nol-producing state in the nation.
According to the Iowa Renewable
Fuels Association (IRFA), the state
has the ability to produce 3.3 billion
gallons of ethanol per year.  Wiki-
pedia states that in 2008, the  92,600
farms in Iowa produced 19 percent
of the nation's corn and 17 percent
of the soybeans. Living in the heart
of corn country, it was a given that
8
                                                        f
motor fuel would con-
tain ethanol.  One  of
Tom and Paul's big
challenges was to find a
way to ensure that fuels
containing ethanol and
soy-based diesel fuels
are compatible with the
UST systems in which
they are stored.
    The use of ethanol
in fuels is complicated
and can be downright
frustrating for UST reg-
ulators, the automobile
industry, tank owners,
installers, and  equip-
ment manufacturers
alike. The Iowa tanks
program epitomizes the
tangled web of com-
peting economic and
environmental interests
surrounding growing,
marketing, and retailing
corn and soybean motor
fuels.
    Yet in all of this,
UST systems  seem to be
the forgotten step chil-
dren—children that can play havoc
with our groundwater resources if
they are not  up  to the task of stor-
ing and dispensing the fuel put into
them without leaking their contents
into the environment. It is the com-
patibility thing. With lower ethanol
percentage levels (e.g., E10), gaskets
and seals tend  to be the primary
problems. At the other end  of the
spectrum (e.g., E85), soft metals such
as brass and aluminum are affected.
The mid  ranges (e.g., 25-30 per-
cent ethanol) are the most difficult
because they can experience both
sets of problems.
    Tom and  Paul have become the
"Who ya gonna call?" guys  if you
have questions about ethanol-blend
motor fuels. As Marcel noted, "When
I first started looking into ethanol on
the Web several years ago, I  ended
up pretty quickly at the Iowa web-
                                                        Pat// Nelson (left) and Tom Collins with the Iowa DNR Tank
                                                        Program.
                                                                    site." For regulators like Tom and
                                                                    Paul, the big question is, "Is UST
                                                                    equipment ready for ethanol blends
                                                                    beyond  E10?" The solution they
                                                                    landed on tries to answer the ques-
                                                                    tions that need to be asked for stor-
                                                                    ing ethanol fuels—from E10 to E85.
                                                                       As I  heard their names repeat-
                                                                    edly invoked, I knew it was high
                                                                    time to tell their story in LUSTLine.
                                                                    So when  Marcel offered to interview
                                                                    Tom and Paul while doing some
                                                                    training in Iowa, I gave him a hearty
                                                                    thumbs-up. So here's the skinny.

                                                                    Well, We've Got Trouble-
                                                                    It was 2003, Paul  and Tom had been
                                                                    pulling together information on E85
                                                                    for a year or so  in anticipation of
                                                                    undertaking some kind of compat-
                                                                    ibility initiative for the introduction
                                                                    of E85. But when a just-filled 6,000
                                                                    gallon stiP3® UST, 1988 vintage,
                                                                    emptied  out overnight, their inter-

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                                                                              December 2010 • LUSTLine Bulletin 66
est in ethanol compatibility with
tank systems reached new heights,
particularly when they learned that
the owner  had just filled the tank
with E85. "That's when we decided
we should be doing some  serious
research and talking to people who
knew," said Tom.
    Around that time, Paul had occa-
sion to talk to a fuel marketer who
called him about some other issues.
Paul took the opportunity to inquire
about ethanol. "He had C stores, and
he also delivered fuel. He told me
about the first time he was going to
deliver E85. He was going to make
the delivery early in the morning, so
he filled the truck the night before.
When he went out the next morning
to deliver the load,  he knew some-
thing was wrong because he could
smell fuel. There were little puddles
under his truck. The rubber gaskets
were just dripping with fuel.  He
ruined a delivery hose too. So that's
when he discovered that E85 was not
normal gasoline," said Paul. "It was
a whole learning process for him,
and we figured we had some learn-
ing to do too."
    "We knew there were UST issues
with E85," said Tom, "but we hadn't
even thought about trucks and vehi-
cles. From talking with our market-
ers and service techs we realized that
we didn't  have  to convince these
people that there were issues. But
there were other stakeholders who
didn't know much about UST issues
that we had to address as well."
    E10 has been in Iowa's gaso-
line since the late 1970s, back when
ethanol and UST-system compat-
ibility weren't on anyone's radar.
But there had been issues  back then,
too. "We were talking to one tank
owner," recalled  Paul, "and he said
'well yeah, back  when we switched
to E10 we  had a lot of  dispenser
leaks.' And they usually  happened
within the first 24 hours.. .didn't take
too long. All of sudden they started
leaking, because it was all  just a little
bit different, it wasn't compatible.
When we talked  with the dispenser
manufacturers while researching
compatibility, their concern was the
gaskets shrinking or growing due to
a change in fuel with different char-
acteristics."

The Road to the Big Meeting
Predictably, there was considerable
industry interest  when the DNR
invited the ethanol stakeholders
to attend some preliminary meet-
ings addressing E85 compatibility
with UST systems. "Some legislators
heard about this initiative and sat in
on some of our early meetings with
the renewable fuels people, even
though we weren't planning any
additional rulemaking," said Paul.
    Tom and Paul have become the
     "Who ya gonna call?" guys if
   you have questions about ethanol-
         blend motor fuels.
    "We didn't want anybody to be
surprised by what we were doing,
so we explained the reasons why we
had to do something about compat-
ibility. As we were  doing our pre-
sentation, I noticed some legislators
were  nodding their heads up and
down," recalled Paul. "And when
we went over to the statehouse and
met more legislators, they seemed
to understand. Some of them were
fairly receptive right  from the start."
    There was a big  reason why the
legislature was receptive:  they'd
already gone through one round of
discovering and cleaning up leaking
underground storage tanks, and they
didn't want to go through it again.
In the late 1980s, at the start-up of
the state's cleanup fund, there was
a decision to identify pre-existing
conditions at UST facilities through
invasive sampling, in  an attempt to
get all facilities back to a clean slate.
It was a real eye-opener. There was a
lot of contamination.
    But the  legislature was just
part of the work that Tom and Paul
needed to do. "The ethanol interests
did not want to see us restricting
the use of ethanol,"  explained Tom.
"The national Renewable Fuels Asso-
ciation (RFA) was pretty emphatic
about that."
    When they first determined that
they needed to do something about
compatibility, Paul and Tom con-
tacted the tank installers association
for help  in researching the  issues.
They called around the states to see
what they were doing. They talked
to equipment manufacturers, includ-
ing everyone from the tank manufac-
turers to the people that make pipe
dope.
   "I mean we contacted every-
body," said Paul. "We tried to get a
timeline on when various ethanol-
compatible components were being
manufactured and installed."
   With the information they had
amassed in hand, they drafted a plan
for what they thought needed  to
happen. "Underlying  our proposal
was our own recognition that we are
not the experts," said Tom, "and we
don't have time to review all the tank
systems in the  state...there's only
two  of us. So we thought the best
route to go was to have the installers
check over the UST systems.
   "At  first, when we ran that idea
by the installers," continued Tom,
"they kind of went 'ehhh,' because
they  didn't really want to do it. They
didn't want the liability of declaring
a storage system compatible. So we
explained that all they'd be doing
was determining whether the equip-
ment at  a facility was or was not on
the manufacturer's list of compat-
ible models and serial numbers. That
was a lot easier for them to swallow.
Once we were at the point where we
finally had our proposal, we were
ready for the big meeting."

The Big Meeting
At the time (2005), the DNR had an
energy section (now its own Office
of Energy Independence) that was
actively promoting renewable fuels.
Tom and Paul asked them to iden-
tify and invite key players to the big
meeting. Energy made the contacts
and set  up the meeting for them. It
would be held at the Farm Bureau's
executive meeting room in West Des
Moines. "It was a very fancy meet-
ing room, a little intimidating rela-
tive to what we were used to, but we
thought it would be a good idea to
hold the meeting on their home turf
rather than at our offices," said Tom.
   "We had a huge representa-
tion," said Paul. "The major state
UST  insurance company (PMMIC)
and other insurance reps, petroleum
marketers, weights and measures,
the national  and state  renewable
fuels people, the state fire marshal,
the corn growers association, the
soybean association, ethanol refin-
ery people, the co-ops—the ones that
               • continued on page 10

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LUSTLine Bulletin 66 • December 2010
• Ethanol Compatibility
from page 9

store  the corn and are most inter-
ested  in selling the fuel—were there,
and more. We presented our infor-
mation and what we thought we
needed to do.
    "We figured there'd be push
back from renewable fuels and other
concerns, which there  was,"  said
Paul.  "So we were just trying to get
everyone together and let them
know what direction we were going.
We told the soy people we couldn't
find any problem with B2, which is
what  they were concerned about. So
that was easy.
    "The national RFA guy kept
insisting there wasn't a compatibility
problem. He made a strong pitch for
ethanol, saying how our information
was not researched or not proven,"
Paul said. "Well many of the people
in the room knew that we had done
our research because we had talked
to them directly. We knew we were
on solid ground because we'd got-
ten our information from the manu-
facturers and the people who made
the equipment and the people who
installed and operated it.
    "We weren't about to sit there
and say, 'oh, let's just  ignore the
people who know  their equip-
ment.' So we listened politely, but
we weren't about to back off,"  Paul
asserted. "And we knew the mar-
keters and installers  were behind
us because  they were  the ones who
were going to be liable for the leaks,
not the farmers, refiners,  or the RFA.
We were regulators doing our job
to protect the environment, but this
was one time when we were protect-
ing the marketers and  installers too.
They didn't want leaks either."
    "Paul and Tom made sure they
talked to the people  who had the
real-world experience and could give
them  real-world information," said
Marcel. "They already had a remark-
able level of trust with the industry
and the regulated community and
saw each other as allies in the quest
to store ethanol safely."

Connecting, and More
Connecting
So that was the first  meeting and
soon Paul and Tom were being asked
to speak at other places  around the
state about what ethanol might mean

10
for owners, operators, and install-
ers. "The marketers don't like being
pushed to do anything," said Tom.
"In this case, they figured they had
everything to lose and not much to
gain by storing E85 in incompatible
storage systems. And so they were
supportive of making sure that what
was going to happen made sense for
them and not just for the farmers.
    "Same thing with the people
installing the equipment," he added.
"They had the most skin in the game.
Even though they were initially a
little leery of our proposal  to have


  "Our drumbeat was, 'Look, we have
  some 8,000 tanks at2,800 sites, and
  we don't want the public put at risk.
   We don't know for sure what could
  happen with E85, so we're looking at
  a worst-case scenario.'And one thing
   good too, we already had federal
    rules that said the fuel has to he
           compatible."
                      —Tom Collins


them be the ones to go out there and
inspect to see what  needed to  be
done to make the UST systems com-
patible, we eventually ended up get-
ting to a win-win solution."
    Tom and Paul  had other meet-
ings at their office and at legislative
offices. Eventually, Tom gave a pre-
sentation to the Environment Com-
mittee.
    "That was kind of a turning
point," said Tom. "After that they
kind of let us alone. They said, okay,
it looks like you guys know what you
are doing, so we'll let you go ahead.
We met with a few other legislators
afterwards, but their concern was
mostly that they don't want to have
leaks anymore. Our drumbeat was,
'Look, we have some 8,000 tanks at
2,800 sites, and we don't want the
public put at risk. We don't know for
sure what could happen with E85,
so we're looking at a worst-case sce-
nario.' And one thing good too, we
already had federal rules that said
the fuel has to be compatible."

The Pre-Ethanol System
Check
Because the rules already required
compatibility, Paul  and Tom figured
they didn't need to do any rulemak-
ing. Their task was to figure out a
way to establish whether a storage
facility was compatible or not. The
centerpiece of the guidance that they
developed was a storage system
ethanol-compatibility checklist. The
checklist is a meticulously honed
mechanism for ensuring that all UST-
system components are compatible
with the product being stored—in
this case, any fuel containing ethanol
blends higher than E10. It is a check-
list that must be filled out and signed
by a licensed Iowa installer. (All of
this information  and  more can be
found at iviviv.ioivadnr.gov/land/ust/
technicalresourceslethanol.html.)
    "The beauty  of this list,"
explained Marcel, "is that all the
installer needs to do is check serial
numbers and model numbers for the
UST-system components to make
sure they are compatible. They aren't
saying this equipment is fine, they're
saying,  this  equipment is on the
manufacturer's list as  being accept-
able. Parts that aren't compatible
need to  be replaced before ethanol
can be stored."
   Tom and Paul enlisted the
experts to help them define compat-
ibility. Installers Al Hilgren with Sen-
eca Petroleum and Terry Cooper with
Acterra Group got very involved in
developing the list, essentially taking
the lead in researching equipment.
Once they had the checklist and all
that went with it, many in the indus-
try, including the state  renewable
fuels people, were given the oppor-
tunity to comment.
    "We didn't do anything in secret
or private," said Tom. "Everything
was out there from the very begin-
ning. Tom Vilsack was governor at
the time and was very supportive.
He just wanted us to solve the prob-
lem. He wanted to make sure that if
he was asked questions  about it he
knew what to say. We gave him talk-
ing points. He did his homework
and became knowledgeable about
the requirements."
   An  Iowa  Renewable  Fuels
Board was created, and they set up
a Renewable Fuels Infrastructure
Program. They could see that replac-
ing certain equipment was going to
be costly and lobbied the legislature
for funding mechanisms (reimburse-
ments, grants, incentives) to help
convert existing systems.

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                                                                              December 2010 • LUSTLine Bulletin 66
    Tom and Paul sent a letter to
the regulated community, letting
them know about the ethanol guid-
ance document and the checklist.
The Iowa Renewable Fuels Board
got behind the checklist and became
very supportive. Tom and Paul
pulled in installers and other stake-
holders to figure  out ways to help
the Board spend the money the leg-
islature put aside to upgrade E85
equipment infrastructure. "We could
help identify the equipment that
needed replacement, and the Board
had the money to help pay for the
new equipment,  so it was a great
combination," said Tom.
    The fire marshal's  office was
concerned with  dispensers and
crash valves, some of which might
still have brass  components. The
DNR had jurisdiction over the dis-
pensers from the ground down; the
fire marshal's office ruled from the
ground up. There were no dispens-
ers listed by UL for E85 service, so
the fire marshal liked the idea of the
checklist as a backup measure. For
their part, the DNR required E85
dispensers to have under-dispenser
containment that was to be checked
daily until such time as the dispenser
was UL-listed. Tom and Paul were
uncomfortable with the fact that they
were allowing this and that it could
have been a public safety issue.
    "You try to come up with some-
thing that works for everybody—
and the environment," said Paul.
"We hashed out issues, like, what if
you don't know what kind of pip-
ing dope and  glue was used when
the system was installed? So how are
we supposed to determine that? We
covered these things in the checklist,
but sometimes with cautionary notes
rather than hard and fast answers."

Moving Forward with What
You Know
Right now, there are about 135 facili-
ties in Iowa that sell E85. You would
think that Tom and Paul went to an
awful lot of trouble to pave the way
for a relatively few facilities, but, in
fact, their running the gauntlet pro-
vided the legwork and a jumping off
point for many other states and the
USEPA.
    Tom and Paul worked hard to
create a mechanism to prevent UST-
system releases brought about by
vulnerable UST-system components.
In the end, they laid out what they
knew in black and white, with a few
gray areas still remaining. "You can
only go with the information you
have," says Paul, and he and Tom
remain cautious.
    "We read a lot of Society of Auto-
motive Engineers (SAE) reports,"
noted  Tom. "Man the  stuff they
found. No wonder they are cautious
with E15. There are a lot more things
to look for in an engine than we look
at in underground storage systems."
    Tom and Paul are not aware of
any major releases in the state due
to ethanol, but they are  aware that
ethanol is having an effect on some
equipment. (See Paul's note in From
Our Readers below.) "Things  we
didn't anticipate," said Tom, "like
the surface corrosion that we're see-
ing on a lot of components. We still
have our ear to the ground in case
something pops up, but so far, things
seem to be okay. "

The E15 Question
"Now that E15 looks like it will be
playing a role in our fuel future, do
you have any thoughts on E15 com-
patibility?" asked Marcel.
    "Well, a great deal of the equip-
ment in the ground is only listed
for E10," says Tom, "so our thought
right now is to tweak the checklist a
bit so it can be applied to any storage
system that is to be used for E15 or
any other blend above E10."
    "We still would rather be safe
than sorry," adds Paul.

Postscript
"Last question," said Marcel  as he
wrapped up the interview, "are you
pleased with the results?"
    "I think it worked out," said
Paul.
    "It seems to have worked out
well," echoed Tom.
    "At first blush, I would  have
thought that attempting to regu-
late ethanol in a corn state like Iowa
was a recipe for disaster. I think that
things have worked out well because
of who these guys are,"  said Marcel.
"They not only understand the tech-
nical issues, they  have a deep under-
standing and respect for their fuel
marketers and tank workers. This
shows in the ease with which Tom
and Paul,  and the people they  regu-
late, communicate with each other.
Tom and Paul listen and come across
as very non-threatening. They  are
not know-it-alls, but they do their
homework, they know what they are
talking about, and they seek  com-
mon-sense solutions. The industry
people respect that. And that mutual
respect creates an  environment
where things can  get done." •
  Reminder:
  If you are seeing unusual corrosion in E10 orE85 sumps, please contact Andrea
  Barbery at OUST (tiarbery.andrea@epa.govj and she will coordinate with you
  and USEPA's Office of Research and Development to arrange for a sump sam-
  pling kit to be sent to you. Data from these sampling kits will be collected and
  analyzed to understand what is causing this corrosion.
I     found the article in LUSTLine ("Not for the Squeamish," LUSTLine
     #65) interesting since we noted the corrosion problem in the sumps
     with ethanol several years ago at the National Tanks Conference. Our
  hypothesis at the time was that it was caused by vapors, though we did
  not pursue an explanation. We had been seeing it for years with the most
  severe having huge flakes coming off. No releases can be attributed to
  the corrosion though. Evidently no one was listening or paying attention
  at the time. The discussion was mainly about E85 and most people had
  yet to see the problem in E10.
                                                        Paul Nelson
                                     Underground Storage Tank Section
                                  Iowa Department of Natural Resources
                                                                                                      11

-------
LUSTLine Bulletin 66 • December 2010
Ferreting Out the Identity of Gasoline
Additives
by Jim Weaver and David Spidle
      Chemical dispersing agents for
      oil spills, hydraulic fractur-
      ing fluids for natural-gas pro-
duction, and chemicals serving as
gasoline additives share a common
characteristic—for the most part,
they are proprietary  compounds.
In the name of competitive advan-
tage, companies carefully guard the
chemical recipes of these products
and are allowed by the federal gov-
ernment to claim "confidential busi-
ness information"  (CBI) status for
them. As a consequence, there could
be additives  in released fuels that
cause future heartburn for the LUST
program.
   The  word "could" must be
emphasized because, for a compound
to cause a problem, it would have
to be present in sufficient concen-
tration in a fuel, have  high enough
water solubility to enter an aquifer,
have low enough degradation to per-
sist, and be toxic at the concentration
where a receptor would encounter it.
Although these criteria present a high
bar to pass, we can look to the lead
scavenger ethylene dibromide (EDB)
as a past example of an additive that
is indeed a continuing  problem (see
LUSTLine #47).
   The complexity of additives can
be seen in USEPA's additive registra-
tion  form, which lists 50 purposes
for gasoline additives (http://iviviv.
epa.gov/oms/regs/fuels/forms/3520-13.
pdf).  These include  detergents, anti-
oxidants, metal deactivators, corro-
sion inhibitors, and anti-icing agents,
among many others. The concentra-
tions of these additives in gasolines
can range from low parts per million
(ppm) to low percent levels. For com-
parison, benzene in reformulated
gasoline is currently limited  to less
than 1 percent or 7,500 ppm, much
higher than the majority of additives.
   The chemical classes of additives
include petroleum fractions, low
molecular-weight alcohols, complex
binders, organometallic compounds,
surfactants,  and polymers (VFJ,
2006). "Classic" additives, as defined
by VFJ, are those with known chemi-

12
cal, toxicological, and environmen-
tal risk properties, which tend to be
compounds that have been used in
gasolines over a long period of time.
Newer compounds tend to be surfac-
tants, polymers, and organometallics
(VFJ, 2006).

Chemical Analysis
Some additives have been  identi-
fied in fuel handbooks, automotive
industry conference proceedings,
and journal  papers, but many are
publicly unknown. Lack of  chemi-
cal identification coupled with the
variety and complexity of these com-
pounds, makes chemical analysis a
daunting task. Despite the difficul-
ties, two approaches have been tried.
   The first approach is to equili-
brate gasoline with water and
analyze the extracts by liquid chro-
matography/mass  spectroscopy.
This was done for a set of Swiss gas-
olines by Torsten Schmidt and col-
leagues at the Swiss Federal Institute
of Technology in Zurich (Schmidt et
al., 2002). The work resulted in a list
of 17 polar compounds that have a
high tendency to partition to ground-
water. Assessment of the partition-
ing behavior of these compounds
led to an approximate approach for
estimating their concentrations in
groundwater. The results showed
that many of these chemicals have
high water solubility and would be
released from their source gasolines
relatively rapidly. Thus, they may
not persist in the gasoline itself.
   In a roughly similar hunt for
compounds, Weaver et al. (2009) ana-
lyzed fuel-grade ethanol and looked
for impurities. A number of higher
molecular-weight alcohols were
found and are listed in Table 1, along
with Schmidt's set of compounds
and a number of additives  identi-
fied in other literature. Notably for
both of these projects, the focus was
on identifying constituents, but not
their toxicity.
   A second approach looks from
the top down. In Denmark, five
major petroleum companies revealed
the identity of additives they were
using to a consulting firm, which
agreed to keep the identities of the
compounds confidential unless a
simplified  screening determined
that they might cause ill effects (VFJ,
2006). The companies identified
around 100 compounds and of these,
eight were identified as potentially
harmful. These compounds are listed
in Table  1 alongside the chemicals
identified from the "bottom up."

Questions from LUSTIand
In the United States, all gasoline and
diesel motor-vehicle fuel additives
are required to be registered in accor-
dance with the regulations in 40 CFR
79. USEPA requires that the producer
provide information on the chemical
composition and methods of analy-
sis for determining the presence of
each compound and  impurities. The
manufacturer is also asked to submit
any information it has on "the effects
of this fuel additive on all emissions;
the toxicity and any other public
health or welfare effects of the emis-
sion products of this fuel additive."
In a few cases, USEPA has required
that these fuels and fuel additives
be tested for possible health effects,
notably ethanol, ethers, MMT, and
cerium-based additives for diesel
fuel.
   However, the manufacturer  can
assert that the product information
is CBI, and, presumably, many do. So
although USEPA holds composition
information on registered additives,
CBI information cannot be disclosed
to the public, including LUST pro-
gram managers, and besides that, the
health effects from ingestion of water
are likely to be unknown unless well-
studied chemicals are involved.
   USEPA and/or outside groups
have questioned the need for CBI
claims for oil  spill dispersants,
hydrofracking fluids, and chemicals
in commerce  (Hogue, 2010). These
increased concerns might  indicate
a future move toward more disclo-
sure of proprietary chemicals. In the
meantime, research is needed on pos-

-------
December 2010 • LUSTLine Bulletin 66
sible impacts of additives in
suggest a program of research
on these chemicals that would
begin to identify additives in
U.S. gasolines. Publicly identi-
fied additives as in Table 1 form
a starting point for a study
of impacts to groundwater.
If these chemicals are found,
then attention can be focused
on their health effects. Both of
these factors — the exposure
and the effects — need to figure
into decisions concerning site
management, and we are only
at the beginning stage of inves-
tigating these chemicals. •
Jim Weaver is a Hydrologist
with USEPA and can be reached
at weaver.jim@epa.gov. David
Spidle is a Research Chemist
and can be reached at
spidle.david@epa.gov .
Disclaimer
This paper has been reviewed in
accordance with the U.S. Environ-
mental Protection Agency's peer and
administrative review policies and
approved for publication.
References
Hogue, C., 2010, Naming names, Chemical
and Engineering News, Volume 88, Number
16,28-31.
Landells, R. G. In Motor Gasoline; Marshall,
E. L., Owen, K., Eds.; RSC: Cambridge,
UK, 1995; pp 170-200.
Owen, K., 1989, Gasoline and Diesel Fuel Addi-
tives, Wiley.
Quimby, B.D., Giarrocco, V., Sullivan, J.J.,
gen and sulfur compounds in gasoline,
/. High Resolution Cheromatography, 15,
705-709.
gel, Kai-Uew Goss and Stefan B. Hader-
lein. Polar fuel constituents: compound
identification and equilibrium partitioning
between nonaqueous phase liquids and
water, 2002, Environmental Science and Tech-
nology, 36, 4074-4080.
Videncenter for Jordforurening (VFJ), 2006,
Fuel additives: A risk screening of addi-
tives to gasoline and diesel, Teknik og
Administration Nr. 3. 2006. http://zozozo.
avjinfo.dk/filerludgivelserlrapporterl37l
Teknik og Administration Nr. 3 2006.pdf.
pdf.
Weaver, J.W., S. A. Skaggs, D. L. Spidle, G. C.
Stone, 2009, Composition and Behavior of
Fuel Ethanol, EPA/600/R-09/037.
http://u7wio.epa.gov/athens/publications/reports/
Weaver_EPA600R09037_Composition_Fuel_
Ethanol.pdf.

TABLE 1. SOME PUBLICLY IDENTIFIED GASOLINE ADDITIVES
1 Class 1 Chemical 1 CAS* No 1 Note 1 Source

Aromatic
Amines
Aliphatic
Amines
Phenols
Benzotri-
azoles
Poly phenol
(sch iff base)
Thiophenes
Alcohols
Ester
Ester-Acid
Neutral
orgamcs
Undesignated
aniline
p-toluidine
o-toluidine
3,4-dimethylaniline
2,6-dimethylanaline
diethanolamine
triethanolamine
phenol
p-cresol
o-cresol
3,4-dimethylphenol
2,6-dimethylphenol
3,4,5-trimethylphenol
2,6-di-tert-butylphenol
benzotriazole
1 -methyl benzotriazole
N,l\l-disalicylidene-
1,2-diaminopropane
thiophene
benzothiophene
methanol
ethanol
1-propanol
2-propanol
isobutyl alcohol
2-methyl 1-butanol
3-methyl 1-butanol
2-ethyl 1-hexanol
2-butoxy ethanol
ethyl acetate
1,2-bis(2-ethylhexyloxy-
carbonyl) ethanesulpho-
nate potassium salt
1,1-diethoxyethane
2-ethylhexyl nitrate
tetrapropylenebutanedioic
acid
di-sec-butyl-p-phenylene-
diamine
1-propene, 2-methyl-
homopolymer, hydro-
formylation products,
reaction products with
ammonia
(Z)-4-oxo-4-
(tridecylamino)-2-butenoic
acid
polyolefin mannich base
62-53-3
106-49-0
95-53-4
95-64-7
87-62-7
111-42-2
102-71-6
108-95-2
106-44-5
95-48-7
95-65-8
576-26-1
527-54-8
128-39-2
95-14-7
13351-73-0
94-91-7
110-02-1
95-15-8
67-56-1
64-17-5
71-23-8
67-63-0
78-83-1
137-32-6
123-41-3
104-76-7
111-76-2
141-78-6
7491-09-0
105-57-7
27247-96-7
27859-58-1
101-96-2
68891-84-9
84583-68-6
-
Water equilibrated with gasoline
Water equilibrated with gasoline
Water equilibrated with gasoline
Water equilibrated with gasoline
Water equilibrated with gasoline
Potential environmental impact
Potential environmental impact
Water equilibrated with gasoline
Water equilibrated with gasoline
Water equilibrated with gasoline
Water equilibrated with gasoline
Water equilibrated with gasoline
Water equilibrated with gasoline
Identified additive
Water equilibrated with gasoline
Water equilibrated with gasoline
Water equilibrated with gasoline
Identified additive
Water equilibrated with gasoline
Identified additive
Fuel ethanol analysis
Fuel ethanol analysis
Fuel ethanol analysis
Potential environmental impact
Fuel ethanol analysis
Fuel ethanol analysis
Fuel ethanol analysis
Potential environmental impact
Potential environmental impact
Fuel ethanol analysis
Potential environmental impact
Fuel ethanol analysis
Potential environmental impact
Potential environmental impact
Identified additive
Potential environmental impact
Potential environmental impact
Potential environmental impact
Schmidt etal, 2002
Schmidt etal, 2002
Schmidt etal. ,2002
Schmidt etal. ,2002
Schmidt etal. ,2002
VFJ, 2006
VFJ, 2006
Schmidt etal. ,2002
Schmidt etal. ,2002
Schmidt etal. ,2002
Schmidt etal. ,2002
Schmidt etal. ,2002
Schmidt etal. ,2002
Landels, 1995
Schmidt etal. ,2002
Schmidt etal. ,2002
Schmidt etal. ,2002
Quimby etal, 1992
Quimby etal, 1992,
Schmidt etal. ,2002
Weaver etal., 2009
Weaver etal., 2009
Weaver etal., 2009
VFJ, 2006
Weaver etal., 2009
Weaver etal., 2009
Weaver etal., 2009
VFJ, 2006
VFJ, 2006
Weaver etal., 2009
VFJ, 2006
Weaver etal., 2009
VFJ, 2006
VFJ, 2006
Owen, 1989
VFJ, 2006
VFJ, 2006
VFJ, 2006
* CAS = Chemical Abstracts Service.

                             13

-------
LUSTLine Bulletin 66 • December 2010
FOOTPRINT
A New  Tool to Predict the Potential Impact of
Biofuels on BTEX Plumes
by John Wilson


        Most of us know that BTEX compounds can biodegrade in groundwater, and many of us incorporate this natural biodegra-
        dation into our strategy to manage risk at sites where there has been a gasoline release. In the absence of natural biodeg-
        radation, many BTEX plumes would be much larger than they are. Unfortunately, biofuels can interact with BTEX and
inhibit this natural biodegradation, further complicating an already complex picture.
A Bit of History
More than a decade ago, ground-
water scientists and engineers
raised the possibility that ethanol
could inhibit natural biodegrada-
tion of benzene, toluene, ethylben-
zene, xylenes (BTEX) compounds
(Corseuil et al., 1996, Powers et al.,
2001). If this is true, a spill of E10
should have a longer BTEX plume
than a spill of conventional petro-
leum gasoline. To see if this really
happened at gasoline station sites,
Ruiz  et al. (2003) compared the
lengths of benzene plumes at 217
sites in Iowa, where gasoline releases
did not have ethanol, to the length of
benzene plumes at 29 sites in Kan-
sas, where the releases had E10. On
average, the benzene plumes were 39
percent longer at the E10 sites.
   To further evaluate this poten-
tial impact of ethanol on the size of
BTEX plumes, Mackay et al. (2006)
did a side-by-side experiment to
compare the effects of ethanol at the
same release site. They constructed
artificial plumes of BT and X. Both
had approximately 1 to 3 mg/L of
benzene, toluene and o-xylene. One
plume had 500 mg/L ethanol, while
the other had none. After the plumes
reached a steady state,  the BTX
plume in the presence of ethanol was
four  times longer than the plume
without ethanol.

A Conceptual Model to
Predict the Impact of Ethanol
Deeb et al. (2002) developed a con-
ceptual model that can be used to
make quantitative predictions of
the effect of ethanol on the length of
the BTEX plume. In contaminated
groundwater there is very little oxy-
gen available, and anaerobic bacteria


14
carry out almost all of the natural
biodegradation. After all the soluble
electron acceptors such as nitrate or
sulfate  are exhausted, the only pro-
cesses assumed to attenuate BTEX
concentrations are physical, such as
dispersion and sorption, and anaero-
bic biodegradation, which proceeds
through  a fermentation reaction
that produces acetate and molecu-
lar hydrogen. If the concentration of
hydrogen builds up to a critical level,
the thermodynamics  of the  BTEX
degradation becomes unfavorable,
and the degradation stops. Ethanol
in groundwater is also fermented to
acetate and hydrogen.
   When the  concentrations of
ethanol are above 3 mg/L, natural
degradation of ethanol can produce
enough molecular hydrogen to stop
the natural anaerobic biodegradation
of BTEX compounds. In the Deeb et
al. conceptual model, whenever the
concentration of ethanol is  above
a critical threshold (3 mg/L), the
natural biodegradation of BTEX is
prohibited. In the region of an aqui-
fer where concentrations of ethanol
are above the threshold, the only
processes that attenuate the concen-
trations of BTEX are dispersion and
sorption. However, ethanol degrades
in the groundwater, and eventually
to a concentration below the thresh-
old. At that point along the flowpath
in the aquifer,  the model assumes
that natural biodegradation of BTEX
proceeds at the same rate that  would
prevail in the aquifer if ethanol had
not been released.

FOOTPRINT
Ahsanuzzaman et al. (2008) used
the Deeb et  al. (2002) conceptual
model to  construct a simple screen-
ing model to estimate the area of a
plume of benzene produced from a
release of gasoline containing etha-
nol. The screening model estimates
the plume area, or footprint of the
plume, in addition to the plume
length, because the chance  that a
plume will impact a monitoring well
is proportional to its surface area,
not its length. FOOTPRINT is built
around the Dominico analytical solu-
tions to the advection dispersion
transport equation (Dominico, 1987;
Martin-Hayden and Robbins, 1997).
This is the same mathematics that is
used in BIOSCREEN, a widely used
fate-and-transport model.

Applying FOOTPRINT to a
Vulnerable Site
Every plume is different. The ques-
tion is:  What will ethanol  do to
plume lengths at sites in your case
load? To illustrate  the potential
impacts of a biofuel spill, FOOT-
PRINT was calibrated  to a large
BTEX and MtBE plume at Naval
Base Ventura County, in Port Huen-
eme, California.
•  In the first step, FOOTPRINT
  was calibrated without any effect
  of ethanol. (Note  the check box
  labeled COC Only [No Ethanol]
  in the lower right of Figure  1.)
  If FOOTPRINT is appropriately
  calibrated, the simulated output
  should adequately mirror the real
  benzene plume at the site.
• In the second step, the poten-
  tial impact of a new biofuel spill
  was  simulated by assuming a
  relatively high concentration of
  ethanol and an average rate of
  biodegradation for ethanol.
• In the third step, a potential worst
  case was simulated by assuming

-------
                                                                                   December 2010 • LUSTLine Bulletin 66
   a slow rate of biodegradation for
   ethanol.

    This  site was chosen because
it  is representative of sites where
groundwater is highly vulnerable
to contamination from gasoline. In
the mid-1980s there was a release
of approximately  10,000 gallons
of motor gasoline from the Navy
                                    ethanol extends deep into the water-
                                    table aquifer.
                                        The input  menu window for
                                    FOOTPRINT accounts for these fac-
                                    tors (Figure 1). The  site has been
                                    particularly well studied, and it was
                                    possible  to calibrate FOOTPRINT
                                    using input values that were exter-
                                    nally derived. The only assumed val-
                                    ues in the calibrations are the vertical
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                               s 5tt«iirSi»
FIGURE 1. Input screen for FOOTPRINT, simulating the potential effect of ethanol on an exist-
ing BTEX plume at a gasoline spill site in California. In this simulation the rate of degradation of
ethanol was set at 2 mg/L per day or 730 mg/L per year.
dispersivity (which was set at a low
number) and the effective porosity.
    A pumping test and a variety of
slug tests in monitoring wells indi-
cate that the hydraulic conductivity
at the  site is near 100 feet per day.
The hydraulic gradient over nearly a
mile of the flow path was 0.0028 foot
per foot. A tracer study using deuter-
ated MtBE (Amerson and Johnson,
 2003)  determined that the average
 longitudinal dispersivity was 8.8
 feet and the average transverse dis-
 persivity was 0.82 foot.
     The release produced a pool of
 floating product that was at least
 280 feet wide. The water-table aqui-
 fer is approximately  10 feet thick. It
 is confined by a lower layer of silt
 and clay. The maximum concen-
 tration of benzene at the  site is 5.4
 mg/L. The  first-order rate of bio-
 degradation was extracted from
 data on the attenuation of concen-
 trations of benzene with distance
 along the flow  path, using the
 approach of Buscheck and Alcantar
 (1995). The release was assumed to
 have occurred in 1985, making  the
 plume 15 years old at the time of
 calibration.

                • continued on page 16
Exchange (NEX) service station. The
groundwater seepage velocity at the
site is high, nearly one foot per day.
By 2000, the MtBE plume extended
at least 4,600 feet down-gradient of
the release. In August 2000, the Navy
installed an aerobic biobarrier to
treat both MtBE and BTEX contami-
nation in the plume.  FOOTPRINT
was calibrated to conditions in the
plume just prior to installation of the
treatment system.

Calibration  Details
The  impact of ethanol on the foot-
print of a benzene plume will be
greater under the following condi-
tions: (1) the concentration of ben-
zene in the source is high, (2) the
concentration of ethanol is high, (3)
the seepage velocity of groundwa-
ter is high, (4) the natural degrada-
tion rate of benzene is slow, (5) the
natural biodegradation rate of etha-
nol is slow, (6) the source of ethanol
to groundwater is wide in cross sec-
tion to groundwater flow, and (7) the
Coneemraoon along m* Cmurtne « Ihe Plume
o


\
j;
O -
O

\
\
\
\

D 0 SCO I I-.MI. MOO 2SOO 3000
GBUK* m* i» m*» <*)
                                                      tkMbfo Qiek* OK tie F«ju« to V»* m MS Etcat
                                                                                             "•'
                                    FIGURE 2. Benzene concentration vs. distance along the centerline of the plume for the
                                    FOOTPRINT simulation described in Figure 1. The simulated length where ethanol was pres-
                                    ent above the threshold and degradation of benzene was not allowed was 2,100 feet. The
                                    overall length of the benzene plume was almost 3,200 feet.
                                                                                                             15

-------
LUSTLine Bulletin 66 • December 2010
• FOOTPRINTyrom page 15


    Simulations for a hypotheti-
cal release of motor fuel assumed
that the fuel was 10 percent etha-
nol. Following Deeb et al. (2002), the
calibration assumed that the initial
concentration of ethanol in impacted
ground water was 4,000 mg/L, and
the threshold concentration was set
to 3 mg/L ethanol. Based on experi-
mental work conducted by USEPA
staff at the Kerr Center in Ada, Okla-
homa,  ethanol degradation was
assumed to be a zero-order process.
FOOTPRINT was calibrated with the
rate of ethanol degradation set at 20
mg/L per  day and again with the
rate at 2 mg/L per day. These rates
reflect average rates and slow rates
of ethanol degradation under anaer-
obic conditions respectively.

Results of the Simulations
In FOOTPRINT, the results of the
simulation can be presented in two
different ways. Figure 2 presents
concentrations of benzene along the
centerline  of the plume. Figure 3
maps the surface area of the benzene
plume 15 years after the release of
ethanol.
    Unfortunately,  FOOTPRINT
does not allow the user to scale the
axes in the Figure 3 graphic. As a
result, all the "footprints" look the
same. What changes from one  simu-
lation to the next is the values plot-
ted on the x and y axes. Figure 4
presents the actual distribution of
MtBE and benzene in the aquifer in
2000, and compares that distribution
to the distribution of benzene if there
was no ethanol and the distribu-
tion in the  presence of ethanol. The
charts in Figure 3 were modified and
rescaled to  make the axes in the out-
put consistent with the scale marker
in Figure 4.
    Notice  in Figure 4 that there is
reasonable agreement between the
disposition and surface area of the
real plume  and the simulated plume
without ethanol. This indicates that,
for the purposes of this illustrative
exercise, FOOTPRINT is sufficiently
calibrated to conditions at the site.
If the rate of ethanol biodegradation
is  20 mg/L per day, the presence of
even 4,000 mg/L of ethanol will have
little effect on the size of the benzene
plume. The ethanol only becomes

16
important if the rate of ethanol deg-
radation is slow.
    Table 1 makes the same com-
parisons  as  Figure 4 using  num-
bers instead of shapes. If the ethanol
degrades at an average rate, the sim-
ulated benzene plume is 27 percent
larger with  ethanol than without
ethanol. The  simulated effect is well
within the uncertainty in the model
calibration. If the ethanol degrada-
tion is slow, the benzene plume can
be up to four times larger. The MtBE
plume was seven times larger than
the benzene plume. If the rate of etha-
nol degradation is slow, the  size of
the benzene plume from a new spill
of E10 might approach the size of the
                  Pfume Area Exceeding Taget Concentration

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FIGURE 3. Output benzene plume area for the FOOTPRINT simulation in Figure 1. The simulated
area of the benzene plume was 37 acres.
            Real Plume
 FOOTPRINT Simulation
            Benzene,
             Plume
                                                    Benzene FOOTPRINT
                                                     4,OOOmgJLElhanol
                                                   degrading at 2 mg/L per
                                                           day

                                                    Benzene FOOTPRINT
                                                     4,000 mg/L Ethanol
                                                    degrading at 20 mg/L
                                                          per day
                                                            Benzene
                                                          FOOTPRINT
                                                           no Ethanol
FIGURE 4. A comparison of the distribution of BTEXand MtBE in the plume at Port Hueneme,
California, to the projected distribution of benzene from three separate calibrations of FOOTPRINT.

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                                                                                         December 2010 • LUSTLine Bulletin 66
Actual Plume FOOTPRINT Simulation Surface Area (acres)
Benzene Plume



MtBE Plume

Benzene Plume, no Ethanol
Benzene Plume, 4,000 mg/L Ethanol degrad-
ing at 20 mg/Lperday
Benzene Plume, 4,000 mg/L Ethanol degrad-
ing at 2 mg/Lperday

6.6
8.9
11.3
37
46
TABLE 1.  Comparison of the actual surface area of MtBE and benzene plumes in an aquifer to the
predicted surface areas of the benzene plume as simulated by FOOTPRINT.
MtBE plume that developed at this
site.

Developments in the R&D
Pipeline
Remember that FOOTPRINT is only
a screening model. It is based  on
analytical solutions to the transport
equation. As a result, it must assume
uniform flow of groundwater. Notice
in Figure 4 that the real plume takes
a curved path through the aquifer,
probably following local variations
in hydraulic conductivity. FOOT-
PRINT cannot handle variations in
aquifer properties, and in particu-
lar FOOTPRINT cannot handle the
effects of a pumped well that might
tend to draw in a plume.
    To overcome these limitations,
the groundwater flow model must
be  able  to accommodate point-to-
point variation in  groundwater
velocity. It will be necessary to move
up to a numerical model to describe
the transport of the contaminants in
groundwater and their impact  on
water supply wells. USEPA/ORD is
developing just such  a model based
on flow from LUST  sites to water
supply  wells.  This  model  builds
the characteristics  of LUST-site
releases—gasoline volume, composi-
tion, smear  zone thickness—into the
aquifer-transport model and  then
accounts for mixing of  clean and
contaminated water in the well bore.
Example results from the model were
shown at the 2010 National Tanks
conference and are due for publica-
tion in April 2011. •
NOTE: A Problem with FOOTPRINT
in Excel 2007 and higher. FOOTPRINT
will run in later versions of Excel, but it
runs slowly. ORD is working to bring
out a new version of FOOTPRINT that
will not have this problem.
 John Wilson is a Research Microbiolo-
  gist at the USEPA Office of Research
  and Development in Ada, Oklahoma.
         He can be reached at
   wilson.johnt@epa.gov for advice on
  anaerobic biodegradation ofbiofuels.
 For technical support for FOOTPRINT
  contact csmos.ada@epa.gov. Contact
 Jim Weaver at weaver.jim@epa.gov for
  details of the numerical model he has
         under development.
Disclaimer
The U.S. Environmental Protection
Agency through its Office of Research
and Development funded and managed
the research described here through in-
house efforts. It has been subjected to the
Agency's peer and administrative review
and has been approved for publication as
an EPA document.
References
Ahsanuzzaman, A. N. M., J. T. Wilson, M. Wang,
 and R. C. Earle. FOOTPRINT (a screening model
 for estimating the area of a plume produced
 from gasoline containing ethanol) Version 1.0. A.
 EPA/600/R-08/058 (2008).
Amerson, I., and R. L. Johnson. Natural gradient
 tracer test to evaluate natural attenuation of MTBE
 under anaerobic conditions. Ground Water Monitor-
 ing & Remediation 23(1): 54-61 (2003).
Buscheck, T.E., and C.M. Alcantar. Regression tech-
 niques and analytical solutions to demonstrate
 intrinsic bioremediation, in Proceeding of the 1995
 Battelle International Symposium on In Situ and
 On-Site, April 1995 (1995).
Corseuil, H. X. and P. J. J. Alvarez. Natural bioreme-
 diation perspective for BTX-contaminated ground-
 water in Brazil: effect of ethanol. Water Science and
 Technology 34 (7-8), 311-318 (1996).
Deeb, R. A., J. O. Sharp, A. Stocking, S. McDonald, K.
 A. West, M. Laugier, P. J. Alvarez, M. C. Kavana-
 ugh, and L. Alvarez-Cohen. Impact of ethanol on
 benzene plume lengths: microbial and modeling
 studies. Journal of Environmental Engineering 128 (9),
 868-875 (2002).
Domenico, P. A. An analytical method for multidi-
 mensional transport of a decaying contaminant
 species. Journal of Hydrology 91: 49-58 (1987).
Mackay, D. M., N. R. de Sieyes, M. D. Emarson, K. P.
 Feris, A. A. Pappas, I. A. Wood, L. Jacobson, L. G.
 Justice, M. N. Noske, K. M. Scow, and J. T. Wilson.
 Impact of ethanol on the natural attenuation of ben-
 zene, toluene, and o-xylene in a normally sulfate-
 reducing aquifer. Environmental Science & Technology
 40 (19), 6123-6130 (2006).
Martin-Hayden, J., and G. A. Robbins. Plume distor-
 tion and apparent attenuation due to concentration
 averaging in monitoring wells. Ground Water 35 (2):
 339-346(1997).
Miller, K. D., P. C. Johnson, and C. L. Bruce. Full-scale
 in-situ biobarrier demonstration for containment
 and treatment of MTBE. Remediation Journal 12(1):
 25-36 (2001).
Powers,  S. E., C. S. Hunt, S. E. Heermann, H. X.
 Corseuil, D. Rice, and P. J. J. Alvarez. The transport
 and fate of ethanol and BTEX in groundwater con-
 taminated by gasohol. Critical Reviews in Environ-
 mental Science and Technology 31(1): 79-123. (2001).
Ruiz-Aguilar, G.  M. L., K. O'Reilly, and P. J. J. Alva-
 rez. A comparison of benzene and toluene plume
 lengths for sites contaminated with regular vs. eth-
 anol-amended gasoline. Ground Water Monitoring &
 Remediation 23 (1): 48-53 (2003).
          Tank  Bit
 From PEl's Safety Letter 10/15/10
     Failure to  Communicate  Can Be Dangerous
 A service technician reported a near miss when he went to a job to fix a dispenser
 filter housing. Prior to the visit by the service technician, another employee had
 visited the site and had written "bad" on the front of the housing. The employee,
 however, failed to note the  bad filter housing in the Dispatch  Log. When the ser-
 vice technician was working on the dispenser, he engaged the shear valve with-
 out noticing the sign. When the shear valve was engaged, product was released.
 The spill was minor and  no injuries incurred.  However, the submitting company
 noted that the incident could have been  prevented if  the service technician and
 employee had  engaged  in  better communication. The  employee should have
 added notes to the job's Dispatch Log and thoroughly explained the situation.
 The dispenser should have also been properly tagged on both sides. The com-
 pany  noted  that a red "out of order" wire tag on  the Impact Valve would have
 saved the technician working on the site from an incident. The establishment of a
 lockout/tagout procedure for this scenario is also advisable. •
                                                                                                                     17

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LUSTLine Bulletin 66 • December 2010
The Vapor-Intrusion Pathway:  Petroleum
Hydrocarbon Issues
by Blayne Hartman


   Jt has been four years since my last article in LUSTline on vapor intrusion (LL#53, September 2006). Since then, the vapor-
   intrusion pathway has continued to be a "box-office blockbuster" throughout the environmental community. Guidance doc-
   uments have been released by the Interstate Technology and Regulatory Council (ITRC), ASTM, and more than 25 states.
USEPA is preparing to update its guidance. However, these documents do not have sufficient distinctions between assessing the
vapor-intrusion pathway for chlorinated hydrocarbons (e.g., CHCs, solvents such as TCE, PCE) versus petroleum-related hydrocar-
bons (e.g., PHCs). As a result, vapor-intrusion assessments are being conducted at many PHC sites when recent evidence suggests
they may not be necessary or they are being conducted in a manner that is inappropriate for PHCs. State reimbursement fund man-
agers are concerned that the costs for unnecessary or improperly conducted vapor-intrusion assessments could drain the coffers of
already cash-poor funds. So what to do?
   In this article, I begin with a brief regulatory update on the vapor-intrusion pathway and then address issues specifically related
to PHCs to underscore the distinction between PHCs and CHCs. I refer you to my previous articles written in LUSTline #48 and
#53 for more information on some of the topics covered herein.
Regulatory Updates

•  EPA-OSWER
As of this writing, the draft 2002
EPA-OSWER vapor-intrusion guid-
ance has yet to be updated. In 2009,
the Office of Inspector General rec-
ommended that OSWER identify
the portions of the 2002 guidance
that  need to be updated. A report
released by OSWER in August 2010
summarizes the areas they feel need
to be updated, including:
• Emphasis on a multiple lines of
  evidence approach
• Generic attenuation factors for soil
  gas data
• Collection time period for indoor
  air samples (days or longer)
(See http://www.epa.gov/oswer/vaporin-
trusion/documents/review_of_2002_
draft_vi_guidancejmal.pdf.)

   In a  footnote, this document
states that: "The generalized state-
ments in this document may not per-
tain to the more readily degradable
petroleum  compounds." OSWER
will be releasing a draft version of
the revised guidance in late 2011, and
has committed to releasing a final
version by November 2012.
   Go to OSWER's vapor-intrusion
website for more information: http://
www.epa.gov/oswer/vaporintrusion.
18
•  EPA-OUST
Recognizing  the need for vapor-
intrusion guidance specific to PHCs,
OUST convened a technical work-
group  to  prepare guidance  spe-
cifically for PHCs. The workgroup
consists of EPA-OUST staff, regula-
tors from several states, and repre-
sentatives from industry. The group
plans to assist with the development
of a series of issue papers on various
topics throughout 2011, draft guid-
ance by November 2011, and a final
version by November  2012 at the
same time as the revised OSWER
guidance.

Fundamental  Differences
Between CHCs and  PHCs in
the Vadose  Zone
PHCs behave  differently than CHCs
in the vadose  zone for two primary
reasons. First, volatile petroleum
compounds  biodegrade readily
in the presence  of oxygen and soil
moisture, whereas chlorinated com-
pounds are typically more resistant
to biodegradation. The biodegrad-
ability  of volatile petroleum com-
pounds provides  an effective,
naturally  occurring contaminant-
removal mechanism that inherently
limits the  migration of subsurface
petroleum vapors in most cases.
   Second, petroleum-hydrocarbon
free product is  lighter  than water,
while chlorinated-hydrocarbon free
product is denser. These two key
properties (i.e., biodegradability and
density) lead to significantly differ-
ent subsurface source and transport
behaviors that greatly influence
whether vapors reach the near sur-
face and intrude into structures.
   One final difference to keep in
mind is that PHC fuel products are
mixtures of many hundreds of com-
pounds, many  of  which are also
present in common consumer prod-
ucts other than fuel. Chlorinated sol-
vents are typically only one primary
compound with perhaps some deg-
radation compounds.

Biovapor: A New Predictive
Model Incorporating
Bioattenuation
The most common predictive model
currently used for  vapor-intrusion
applications is the one-dimensional
Johnson-Ettinger (J-E)  model that
USEPA and some states have formu-
lated into Excel spreadsheets (http://
www.epa.gov/oswer/riskassessment/
airmodel/johnson_ettinger.htm). How-
ever, for PHCs this model tends to
significantly overpredict the vapor-
intrusion risk,  primarily because
there is no allowance for bioattenu-
ation. Recently, the American Petro-
leum Institute  (API) funded the
creation of a new Excel version of the
J-E model that incorporates bioatten-
uation, named Biovapor. Dr. George
DeVaull of the Shell Development
Company developed the original for-

-------
                                                                              December 2010 • LUSTLine Bulletin 66
mulation of this spreadsheet and the
new Excel version was developed by
GSI Environmental Inc.
    Biovapor is a user-friendly
spreadsheet that allows prediction of
indoor air concentrations and asso-
ciated risk from soil-gas or ground-
water data (a version for soil-phase
data is being contemplated). It also
performs the back calculation of
calculating allowable soil-gas and
groundwater concentrations from
indoor-air screening levels.
    The model does the calculations
for the individual aromatic com-
pounds (i.e., BTEX, naphthalene), as
well as for aliphatic hydrocarbons.
The model applies bioattenuation
only when sufficient oxygen is pres-
ent in the vadose zone (i.e., aerobic
bioattenuation). It uses a mass-bal-
ance approach to ensure that the
amount of bioattenuation does not
exceed the amount of available oxy-
gen.
    Shaw Environmental reviewed
the model formulations in January
2010 under contract to USEPA ORD.
The formulations were found to be
correct. EPA-ORD is planning to
do its own evaluation of the model.
Meanwhile, Robin Davis of the Utah
Department of Environmental Qual-
ity has compared the model's predic-
tions to actual field data at a number
of sites and found the model's results
to be slightly on the conservative
side (in other words, the model often
underpredicts the amount of attenu-
ation and hence overpredicts the
risk). (See Robin Davis's presentation
at http:llwww. neiwpcc. orgllustlinelsup-
plements.asp.)
    The model is currently available
on the API website (www.api.org).
Instructional classes/webinars are
being planned and will be listed on
the website.

Exclusion (Screen-Out Sites)
Criteria
A primary problem we are facing
with petroleum hydrocarbon sites is
what criteria to use to decide if a site
needs a vapor-intrusion  assessment
if there is not an obvious situation
(e.g., fuel in a basement, petroleum
odor  in a structure). If  existing
OSWER Tier 1 screening distances
of 100 feet are applied both verti-
cally and spatially, combined with
extremely low Tier 2 screening con-
centration, then the vast majority of
sites will be screened in for further
investigation, and few sites will be
screened out. While these criteria
may be appropriate for recalcitrant
compounds, they are not appropriate
for PHCs in most scenarios.
    Robin Davis has  analyzed  a
database of about 170 sites from the
United States, Canada, and Australia
in an effort  to determine screening
criteria for PHCs sites (see LUSTLine
# 61). Her primary goal was to deter-
mine what thickness of clean soil is
necessary for various source concen-
trations to decrease to levels below
LNAPL on groundwater are also
completely attenuated with as little
as eight feet of clean soil between
the source and the receptor, based on
a more limited data set of 76 vapor
samples collected at 16 different sites
(Figure 2).
   For soil vapor concentrations,
Robin has previously written in two
prior PHCs articles (LUSTLine  #49
and  #52) that if three to five feet of
clean,  aerobic soil (oxygen > 5%)
exist, vapors are completely attenu-
ated and the vapor-intrusion path-
way  will not be complete.
                Results for  Dissolved
                     Benzene  &  TPH
    Benzene: 194 exterior/near-slab *•
        35 sub-slab = 229 total

            * VAftef A QHMtrttf P«rt« UfeMWIIflM
     TPH: 68 exterior/near-slab +
        22 sub-slab = 90 total
   • t»M: t*» Yif* t
                                                                I.OM.MO
              5 ft clean overlying soil attenuates vapors associated with
                  dissolved Benzene < 1,000 ug/L, TPH 10,000 ugtL
FIGURE 1. Thickness of clean soil required to attenuate benzene vapors from dissolved benzene
in groundwater and to attenuate TPH vapors from dissolved TPH in groundwater (Robin Davis,
2010).
accepted risk thresholds due to bio-
attenuation.
    She concluded that five feet
of clean soil is all that is required
between source and receptor to fully
attenuate benzene vapors for dis-
solved concentrations of benzene up
to 1,000 fig/L and TPH vapors for
dissolved TPH concentrations of up
to 10,000 fig/L (Figure 1), although
the latter value is based on a smaller
number of data points. Compare her
benzene screening value of 1,000
jUg/L to the value that you  would
get from the current USEPA Tier 2
screening value of 1.5 fig/L: the dif-
ference is a factor of nearly 700 times!
    Robin's database also shows that
benzene vapors volatilizing from
    These exclusion criteria for dis-
solved groundwater concentrations,
free product,  and soil-vapor con-
centrations are being discussed to
screen out PHC sites from further
vapor-intrusion assessment. Califor-
nia recently included some of them
as screening criteria in their new
draft Leaking Underground Fuel Tanks
(LUFT) Manual.

Sampling Issues for PHC
Sites
• Indoor Air Sampling
The August 2010 OSWER review
document mentioned previously dis-
cusses possibly collecting indoor air
samples at the beginning of a vapor-
                • continued on page 20

                              19

-------
LUSTLine Bulletin 66 • December 2010
 I Vapor-Intrusion Pathway from page 19
     Results for LNAPL/Contaminated  Soil
           Vapor umpte event* »tot<*ird wnh LNAPL * euYMnmued »fti meuf CM
                  tl CLEAN «!•%•• Ui
                 npon «McM*d wUi LNAFl en GW ind
                 tell iwrcti
FIGURE 2. Thickness of clean soil required to attenuate benzene vapors from sites with LNAPL
(Robin Davis, 2010).
intrusion investigation. Indoor air
sampling  for PHCs will likely be
problematic and confuse, not clarify,
the vapor-intrusion pathway for two
primary reasons:
• Ambient (outdoor air) levels of
  benzene exceed the screening lev-
  els in most urban areas and can
  exceed the one in one million resi-
  dential  risk levels in many non-
  urban areas. Try explaining to the
  resident why his or her indoor
  air exceeds the allowable cancer
  risk value by 10 times, but that it
  is okay because the air is coming
  from the outside.
• The indoor  sources for  benzene
  and other PHC compounds  are
  ubiquitous  and nearly impos-
  sible  to identify. My  favorite
  recent example that demonstrates
  this point is Bloonie®, a balloon-
  making toy for kids.  It  contains
  obscene amounts of acetone, etha-
  nol, benzene, and other  goodies,
  and you would never  think to
  remove it from a house  if it was
  lying  on the counter. (Read on for
  another example of a ubiquitous
  source of benzene in homes.)

    In recent presentations at vapor-
intrusion-related conferences,
USEPA-OSWER is recommending
longer indoor air sample-collection

20
periods, for periods as long as 7 to
30 days,  based on lessons-learned
from the radon literature. This is not
a good idea for PHC sites because
of the many potential indoor air
sources. The  procedure will result
in numerous  false positives, which
will require a lot of time and  expense
to decipher the actual source of the
detections.
   For the above reasons,  I rarely
recommend collecting indoor air
samples  for  PHCs at residences.
For commercial/industrial recep-
tors, collection of indoor air samples
might be more  suitable depend-
ing on the  allowable indoor levels
(allowable indoor levels can be 10 to
50 times higher than residential lev-
els in some states).

• Groundwater Sampling
Since the existing models and default
attenuation factors do not account
for bioattenuation, you can expect
groundwater  data to  overpredict
the risk for PHC compounds if there
are no sources in the vadose zone.
Hence, I rarely  recommend  that
groundwater samples  be collected
for PHC vapor-intrusion  assess-
ment if soil-gas data can be collected
(sometimes a shallow water table
precludes the collection of  soil-gas
data). However, if groundwater data
already exist and indicate there is no
risk, then it is probably a safe bet that
the pathway is not of concern, and
no further assessment is needed.

•  Soil-Gas Sampling
Sample Depth
PHC  soil-gas sampling locations
differ from those for CHCs owing
to their different fate and transport
behavior. For  PHCs, if  samples at
deeper depths (>5ft bgs) exceed
allowable values, shallower sam-
ples (<5ft bgs) should be collected
for  slab-on-grade structures, since
bioattenuation may be active in the
upper few feet and reduce  values
below acceptable levels. If on-site
analysis  is available, this decision
can be made in real time. However,
if on-site analysis is not  available, I
recommend that my clients collect a
sample shallower than five feet bgs
in the event  that the deeper sample
exceeds allowable levels.
    The incremental cost of collect-
ing the additional samples is negli-
gible. You can withhold analyzing
the shallower sample to see if results
from  the deeper sample indicate
there is a need to analyze it. As far
as the representativeness of shallow
soil-gas concentrations, EPA-ORD
has finished  two studies document-
ing that  the temporal variation of
soil-gas concentrations as shallow as
two feet bgs  are less than 50 percent
(Figure 3). (See http://www.epa.gov/
nerlesdllcmblpdfl270cmb07.pdf.)
    Oxygen  data should always be
collected to document the presence
of the aerobic zone. Carbon dioxide
and methane are also useful to con-
firm the presence of bioattenuation.
Soil-phase data may also be needed
to document the presence of clean
soil.

Sub-slab vs. Near-slab Samples
For CHCs, the current thinking is
that shallow soil-gas data (5 to 10 ft
bgs) collected  outside the building
slab may not adequately represent
sub-slab  soil-gas concentrations in
many  situations. This thinking is
based  on modeling simulations as
well as data from many CHC sites.
But for PHCs, field data currently
being presented by Robin Davis and
Todd Ririe (BP-Arco) at many confer-
ences (http://www.neiwpcc.org/tanks-
conference/pre-workshops.asp) and from

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                                                                            December 2010 • LUSTLine Bulletin 66
            Soil Gas Temporal Study
                        TCE - Probe A3
      o
      "to
      O
      O
      O
      -D
      0>
      N
      lo
  2
1.8
1.6
1.4
1.2
  1
0.8
0.6
0.4
0.2
  0
                                                     17'(Port 5)
                                                     [  3' (Port 9)
                    Time (3/16/07 to 4/10/07)
FIGURE 3. TCE concentrations in soil gas fora period of four weeks for three probes at 3' bgs, 7'
bgs, and 17' bgs (EPA 2007).
  Effect of
  Source
  Concentration
   Results suggest that
   there may be source
   vapor concentrations
   that .11 v oflittle
   concern if soil gas
   beneath the
   foundation is well-
   oxygenated (e.g.,
   •ji I'liini'is :iu i plume
   sources)
                                             '
                                           "•

FIGURE 4. 3-D modeling of hydrocarbon vapors showing the effects of bioattenuation (Abreu &
Johnson, 2006).
modeling simulations suggest that
exterior shallow soil-gas samples are
representative, so long as sufficient
oxygen is present (> 4%) and three
to five feet of clean soil exist under
the receptor (Figure 4). So, near-slab
sampling for PHCs should be a via-
ble approach at most sites, unless
contaminated soils or low oxygen is
suspected under the structure.
                          Including Petroleum
                          Aliphatics as a Compound of
                          Concern?
                          Some states (e.g., MA, CA, WA, HI)
                          have published indoor air screen-
                          ing  levels for the  petroleum ali-
                          phatic range and require that they be
                          included as a compound of concern
                          (COC) for the vapor-intrusion path-
                          way at PHC sites. There is currently
                          considerable debate as to whether
this compound group does represent
a potential health threat. I am not a
regulator making policy, but I will
caution those that do—if aliphatics
are included  as a COC, it is likely
that many more sites will require
a vapor-intrusion assessment. The
reason for this is that the aliphatics
have much higher Henry's constants
and higher vapor pressures than the
aromatics, resulting in much higher
concentrations in the soil gas (by lOx
to 50x) over free product, near dirty
soil, and even near  dissolved con-
tamination.
    The fundamental problem is that
petroleum is made up of many dif-
ferent aliphatic compounds, but the
toxicity data  exist for very few of
them. Hence, applying the limited
existing toxicity data to the total ali-
phatic fraction is an extrapolation.
To better understand  the true risk
of these compounds, it is necessary
that the toxicity of the individual ali-
phatics be reviewed so that the risk-
driving compounds, or compound
groups, are identified and appropri-
ate chemical-specific screening levels
(meaning not too conservative) are
determined.
    If  you are going to measure the
aliphatics, be sure that the laboratory
does the appropriate compound-
group speciation and that it uses
calibration standards for those com-
pounds. Some labs are quantifying
all the aliphatics using one or two
compounds, such as hexane, rather
than purchasing the expensive ali-
phatic mixture standards.

Beware Natural Gas
Earlier this year, while on a vapor-
intrusion investigation, we dis-
covered 90 percent methane and
benzene in the thousands of ]Ug/
m3  under a garage at a home far
removed from the suspected ser-
vice station source. Using real-time
analysis, we collected additional soil-
gas samples and honed in toward
the culprit—a built-in barbeque in
the adjoining courtyard plumbed
directly to the public natural gas. We
next collected and analyzed a sample
of the natural gas itself and were
astonished to find benzene concen-
trations exceeding 1,000 jUg/m3!
    All of the houses in the com-
munity had natural gas fireplaces in
the living rooms, gas furnaces, and
               • continued on page 22

                             21

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LUSTLine Bulletin 66 • December 2010
• Vapor-Intrusion Pathway
from page 21

many had gas ovens/stoves. It turns
out that most natural gas supplied
by gas companies across the coun-
try has 0.1  to 1 percent "impurities,"
meaning hydrocarbons other than
methane. Take-home lesson: if the
receptor has natural gas, analyze a
sample of the natural gas for the tar-
get compounds. This should be done
if indoor-air, sub-slab soil-gas, or
exterior soil-gas data are being col-
lected, since underground gas lines
can also leak.

Parting Thoughts
•  The Two Most  Common Errors  in
Vapor Intrusion
Vapors  and vapor intrusion are an
unfamiliar territory for many prac-
titioners in this field (i.e., regulators,
stakeholders, consultants, subcon-
tractors, attorneys).  Here are two of
the most common errors that I see
being made in this subject area:

•  Confusion with Units
   One  common error that people
   make with soil-gas data is  think-
   ing a ppbv is equivalent to a |Ug/L
   or a  jUg/m3. The units are not
   equivalent, and  the  conversion
   depends on the molecular weight
   of the compound.  Converting
   between units (e.g., |Ug/L to ]Ug/
   m3, percent to ppmv) is also caus-
   ing headaches. Make your life
   simpler by:
   -  Instructing your lab in which
     units and detection levels you
     want the data reported.

   -  Going to www.handpmg.com for
     a handy-dandy and easy-to-use
     unit conversion spreadsheet.

•  Required Soil-Gas Target Levels
   The other error I  see too often is
   the regulator or consultant using
   incorrect  soil-gas target levels.
   Residential values are erroneously
   applied at commercial sites, incor-
   rect attenuation factors are being
   used to  determine target values,
   or values determined from pre-
   dictive models  are incorrect. The
   soil-gas target level ultimately
   determines the required analyti-
   cal method and the need for addi-
   tional assessment. Determining
   the proper value is often an unfa-


22
   miliar exercise for both regulator
   and consultant. So, consultants
   need to ensure that regulators are
   asking for the proper values, and
   regulators need to ensure that
   consultants  are proposing the
   proper values.
    Vapor-intrusion assessments are
   being conducted at many PHC sites
   when recent evidence suggests they
    may not be necessary or they are
    being conducted in a manner that
    is inappropriate forPHCs. State
    reimbursement fund managers
    are concerned that the costs for
  unnecessary or improperly conducted
   vapor-intrusion assessments could
      drain the coffers of already
          cash-poor funds.
   Experience: The Key Ingredient for
Vapor-Intrusion Solutions
The most important ingredient
needed for cost effective, and cost-
efficient vapor-intrusion inves-
tigations is the  experience of the
consultant and the subcontractors
(e.g., sampling firm, laboratory). This
is a growing problem as many practi-
tioners are jumping into vapor intru-
sion due to the opportunities that
exist.
    Sampling errors include such
basics as not opening containers,
incorrect seals,  over-tightening
swage lock fittings, wrong tubing,
using contaminated parts and seal-
ants, and more.  Laboratory issues
consist of sending out incorrect or
faulty hardware, using the wrong
method for the required detection
levels (typically at higher cost), and
more. These mistakes result in bad
data that only further confound the
interpretation.
    I advise responsible parties to
use consultants experienced with
this pathway. In turn, I advise con-
sultants to use firms experienced in
soil-gas collection and use labs expe-
rienced in indoor-air/soil-gas analy-
sis. The stakes are simply too high
with vapor intrusion to do anything
else.
Want to Know More?

• The Nielsen Field School will be
  giving a course on "Soil Gas Sam-
  pling  for Vapor Intrusion Appli-
  cations"  in January 2011 in  San
  Diego. Go to: http:llwww.envirofi-
  eldconference.com.
• API is offering free training enti-
  tled "Assessing Vapor Intrusion
  at Petroleum Hydrocarbon Sites"
  covering the topics discussed in
  this article and more at the AEHS
  conference in San Diego in March
  2011.
• As mentioned previously, API
  will be offering training on the
  Biovapor model throughout 2010
  and 2011. Go to  www.api.org to
  find dates or e-mail me if you are
  interested in such training.
• ITRC continues to offer a two-day
  vapor intrusion course. San Anto-
  nio in January 2011, and three
  other locations (TEA) in 2011. Go
  to www.itrcweb.org for details.
• EPA-OSWER  will be holding a
  1-day workshop on vapor intru-
  sion at the AEHS conference in
  San Diego in March 2011. Go to:
  http:llwww. aehsfoundation. org. •

References
Abreau & Johnson (2006). Simulating the effect of
 aerobic bioattenuation  on soil vapor intrusion into
 buildings: Influence of degradation rate, source
 concentration, and depth. Env.Sci.Tech., 40, 2304-
 2315
LUSTLine articles referenced in this article can be
 found atwww.nenvpcc.org/lustline.
Robin Davis (2010). Slides from her most recent pre-
 sentations at API's "Assessing Vapor Intrusion at
 Petroleum Hydrocarbon Sites" training course.
USEPA (2007). Final project report for investigation
 of the influence of temporal variation on active soil
 gas/vapor sampling. EPA/600/R-07/141, Decem-
 ber 2007.

I wish to thank the following reviewers of
this article for their constructive comments:
Robin Davis, George DeVaull, Larry Froebe,
Tom McHugh, and Todd Ririe.

 Blayne Hartman, Ph.D., is an indepen-
  dent consultant offering vapor-intru-
  sion, soil-gas, and analytical support
  services. He has provided training on
  soil-gas methods and vapor intrusion
  to over 30 state agencies, several U.S.
  EPA regions, ASTSWMO, the DOD,
  and numerous consultants and stake-
 holders. He is a trainer in vapor intru-
  sion courses offered by EPA-OUST,
 ITRC, API, and previously ASTM. For
  more information, contact Blayne at
      Blayne@hartmaneg.com.

-------
                                                                        December 2010 • LUSTLine Bulletin 66
               Using In-Situ Chemical  Oxidation to
               Clean  Up Contamination  at a  Shallow
               Groundwater/Fine-Grained  Soils  Site
               by Samar J. Bhuyan and Michael R. Latin


      The Arizona Department of Environmental Quality
      (ADEQ) developed and implemented a successful reme-
      diation approach to address a challenging set of site-
contamination conditions at a leaking underground storage tank
(LUST) site in Somerton, Arizona. The challenges at the site
involved shallow groundwater, fine-grained soils, and gasoline
contamination in the groundwater, smear zone, and in free-prod-
uct phase. The remediation approach combined in-situ chemical
oxidation (ozone injection) with soil-vapor-extraction (SVE)
technology. The cleanup was implemented through the ADEQ's
State Eead Unit (SLU), Corrective Action Section, Waste Pro-
grams Division. The project was initially funded by state funding
and was completed and closed utilizing federal stimulus money
provided under the American Recovery and Reinvestment Act
(ARRA). Timely completion of this project prevented the spread
of contamination to nearby residential properties and a school.

                         1"T.
                             r
                              m
                                •=/.£
          cS
                                                        j-
                FIGURE 1. Somerton, Arizona, LUST-site map.
The Setting
The previous owner used the prop-
erty as a retail gasoline station dur-
ing the 1980s. In 1987, an unknown
quantity of gasoline escaped from
the UST system into the soil and
groundwater. Of particular concern
was the residential property and the
Desert Sonora Elementary School
located just north and down gradi-
ent of the property. Pump-and-treat
and SVE systems were implemented
by the responsible party in the 1990s
and then terminated without suc-
cessful completion. The responsible
party declared bankruptcy and the
property was sold to the current
property owner.
   In 2006, the property owner
requested state-lead program assis-
tance to complete the corrective-
action work. The  site  lithology
consisted of mostly clay from the
surface to depths ranging between
7 and 11 feet below ground surface
(bgs). Below the clay layer to a depth
of at least 25 feet bgs, a fine-grained,
unconsolidated,  and uniform river
sandy layer was observed.  The
groundwater level at this  site is gen-
erally about 10 or 11 feet bgs.
   Due to  the shallow  nature of
the groundwater, soil contamina-
tion was not the primary remedia-
tion concern. The groundwater had
very high levels of benzene, toluene,
ethylbenzene, and xylene (BTEX).
Arizona's  Aquifer Water Quality
Standard (AWQS) for BTEX cleanup
is 5.0, 1,000, 7,000, and 10,000 fig/L
(ADEQ, 2002), respectively.
   Groundwater fluctuation, corre-
sponding to nearby irrigation sched-
uling, resulted in a smear zone of
contamination. Nine groundwater-
monitoring wells, as shown in the
site map (Figure 1, extracted from
ADEQ's LUST file), were installed at
the site to delineate the groundwater
plume. This contaminated mass was
estimated to have spread to an area
of approximately 8,200 square feet.

The  Methods
The objective of our remediation
approach  was to be as effective
and aggressive as possible due to
the presence of the down-gradient
school and  residential properties. To
do this, we used, primarily, the in-
situ chemical oxidation technology,
reported to be effective in reducing
contaminants in a short time frame
from both the groundwater and the
smear zone (USEPA, May 2004).
   We injected air containing up to 5
percent ozone into the groundwater
for this purpose. Ozone has a very
high chemical oxidation potential of
2.1 V, which is useful for attacking
petroleum contamination aggres-
sively in-situ (ITRC, 2005). The ozone
was injected  at a low pressure and
flow so that the contaminated mass
would be less likely to be pushed
underneath the building on the site.
It also helped minimize the potential
for generating volatiles through the
vadose zone and causing groundwa-
ter mounding. The ozone also dis-
solves readily in groundwater, which
can significantly increase dissolved
oxygen (DO) and enhance biodegra-
dation (USEPA, May 2004).
   Under this approach, developed
by the SLU in 2007, ten 2-inch-diam-
eter injection  wells were installed to
25 feet bgs. They were constructed
with chlorinated poly vinyl chloride
(CPVC) materials and three feet of
stainless-steel screen at the bottom.
The wells were installed in the more
highly  contaminated  source area.
Injection wells were then connected
through subsurface teflon tubing to
the ozone-injection equipment. Tef-
lon  tubings were inserted through
larger diameter (6-inch) PVC pipe
installed in a horizontal trench at
about 4 feet bgs.
              • continued on page 24

                            23

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LUSTLine Bulletin 66 • December 2010
• In-Situ Chemical Oxidation
from page 23

    Due to the shallow depth to
groundwater, a horizontal SVE sys-
tem was implemented. With this
system, we extracted contaminated
hydrocarbon vapors (using a smaller
blower with a 100 standard cubic feet
per minute [scfm] capacity) from the
vadose and smear zones and treated
it through a catalytic oxidizer.
    The horizontal subsurface per-
forated piping consisted  of five
different legs, each constructed of
2-inch-diameter PVC perforated
pipe,  approximately  40 feet long
(Figure 1). During this period,
groundwater dropped  about 3 feet
to approximately 13 feet bgs, result-
ing in the appearance of free product
in three monitoring wells (MW-2,
MW-3, and MW-4; see Figure 2) and
exposure of the smear zone in the
site. These three wells were retrofit-
ted to vapor extraction (VE) wells
and connected to  the  SVE equip-
ment  through  subsurface piping,
in order to extract free-product and
smear-zone contamination. The free
product from the wells  was also
hand-bailed prior to system start-up.

Start-Up
The SVE system was started on May
31, 2007, utilizing three vertical VE
wells  and all five horizontal perfo-
rated legs. The flow rate was initially
Remediation system installation and groundwater-monitoring activity.
98 scfm and later reduced to 40 scfm
due to low hydrocarbon recovery
rate and groundwater mounding
concerns. The ozone injection sys-
tem was then brought into opera-
tion at 2 pounds per day with a flow
rate range of 3.6-4.5 scfm and at a
pressure range of 9-12 pounds per
square inch (psi) through individual
injectors. This ozone injection equip-
ment  was programmed to inject a
mixture  of ozone and air through
one injection well at a time for one
hour,  known as pulsing or cycling.
Each injection well was injecting at
least once per 24-hour cycle. This
pulsing of airflow is reported to be
effective in remediating contamina-
tion (NAVFEC, 2001).

The Outcome
We monitored the progress of this
remediation  by  periodically sam-
pling the groundwater in nine moni-
toring wells (MW-1 through MW-9)
as well as the influent and effluent
to the catalytic oxidizer. During each
groundwater-sampling event, the
remediation systems were turned off
three days prior to sampling to allow
the groundwater to stabilize and to
collect a homogenized sample. Wells
that showed free product were not
sampled. Atmospheric vapor read-
ings across the site did not show any
unusual readings.
   The ozone injection system was
equipped with an ambient  ozone
sensor that detects and measures
concentration of ozone emission.
The equipment shuts down auto-
matically if an ozone leak is detected.
Approximately, 670 pounds of ozone
were injected into the groundwater.
Based on the influent vapor sam-
pling, the SVE system was recover-
ing approximately 10 pounds/day of
petroleum hydrocarbons in the ini-
tial four months of operation, which
was reduced  to 4 pounds/day, and
then to 0.4 pounds/day toward the
end of the remediation.
   The baseline DO measured at
the site prior  to the system installa-
tion was in the range of 0.4 through
1.1 parts per million (ppm). DO lev-
els measured during the remediation
period were as high as 8.9 ppm. This
demonstrated a significant increase
in DO as a result of ozone and air
injections. Four boundary  moni-
toring wells (MW-5, MW-6, MW-7,
MW-9), which were away from the
24

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                                                                                  December 2010 • LUSTLine Bulletin 66
                                     Months
FIGURE 2. Benzene concentration data in a few selected wells. Note: Free product was detected in
MW-2, MW-3, and MW-4 in early 2007.
ozone injection area, also showed
increased DO levels. These wells
were between 40 and 80 feet away
from their nearest ozone injection
well. The location of the boundary
injection wells enhanced bioremedia-
tion in the outer edge of the plume.
    Groundwater elevation  during
the remediation period remained
at approximately 13 feet bgs, which
helped expedite free-product recov-
ery and smear-zone remediation.
The free product contamination dis-
appeared after three months of oper-
ation. Free product was not analyzed
for contaminants of concern (COC).
Sampling below the free-phase
area would have provided  us with
a better understanding  of the total
contaminant  mass. Therefore, the
concentration data shown in Figure 2
cannot be used to estimate this mass.
    Benzene concentrations in most
contaminated wells  are shown in
Figure 2. The COCs from most of the
wells dropped significantly within 8
months of system operation. After 18
months of system operation, results
from the December  2008 ground-
water-sampling event showed  that
COCs in all wells except one, MW-3,
were below AWQS. Active remedia-
tion on the  site was terminated fol-
lowing this sampling event.
    Two rounds of post remediation
groundwater sampling were per-
formed approximately one year after
the termination of active remediation
to test for any rebound of contami-
nants. Confirmatory soil sampling
at two locations was also performed
to test for residual soil contamina-
tion across the vadose  zone. All
COCs were measured below AWQS
and soil cleanup levels. The site was
closed in February 2010.
    It should be noted that bioreme-
diation (natural attenuation) may
have occurred during the post-active
remediation period to address resid-
ual contamination. This remediation
phase  helped reduce remediation
costs as  a result of system opera-
tion and  maintenance, generation of
remediation wastes, and associated
costs for treating residual levels of
contamination. Recently, the remain-
ing infrastructures were abandoned
and the site was restored as close as
possible to its original condition.
    The  successful  results  of this
remediation  approach,  however,
                                    should not be taken as endorsement
                                    for this application in similar site
                                    conditions. Detailed site-specific con-
                                    dition and feasibility tests should be
                                    carefully evaluated before develop-
                                    ing any remediation approach. •

                                      Somar J. Bhuyan, Ph.D., is an Envi-
                                      ronmental Engineer and Michael R.
                                     Latin is the Manager of State Eead Pro-
                                     gram, Corrective Action Section, Waste
                                      Programs Division with the Arizona
                                      Department of Environmental Qual-
                                      ity. Samar J. Bhuyan can be reached at
                                          bhuyan.samar@azdeq.gov.


                                    Acknowledgement: Funding for this project
                                    was provided under Arizona's State Assur-
                                    ance Fund and American Recovery and
                                    Reinvestment Act (ARRA). The remediation
                                    approach was implemented through Ground-
                                    water and Environmental Services, and post-
                                    active remediation activities were performed
                                    through Elaes Environmental Management,
                                    Inc., State Environmental Contractors con-
                                    tracted with State of Arizona. Comments
                                    from Eric Magnan, P.E., Underground Stor-
                                    age Tank Program Office, U.S. EPA Region 9
                                    were much appreciated.


                                    References
                                    Arizona Department of Environmental Quality
                                      (ADEQ), 2002. Release Reporting and Corrective
                                      Action Guidance. Underground Storage Tank Pro-
                                      gram.
                                    The Interstate Technology & Regulatory Council
                                      (ITRC). January 2005. Technical and Regulatory Guid-
                                      ance for In-Situ Chemical Oxidation of Contaminated
                                      Soil and Groundwater. Second Edition, January 2005.
                                    Naval Facilities Engineering Command (NAVFEC).
                                      August 2001. Technical Report. Final Air Sparging
                                      Guidance Document. TR-2193-ENV.
                                    United States Environmental Protection Agency
                                      (USEPA). May 2004. How to Evaluate Alterna-
                                      tive Cleanup Technologies for Underground Stor-
                                      age Tank Sites: A Guide for Corrective Action Plan
                                      Reviewers. EPA510-R-04-002.
                                             • .
Maine  DEP Receives National Award for
Online Operator Training
The  Maine Department of Envi-
ronmental  Protection received an
award for  its  TankSmart online   L
service from the Center for Digi-
tal Government's annual "Best of
the Web" program—Government-
to-business category. The  awards
given for online state government
services are chosen for their innova-
tion  and effectiveness. TankSmart
(www. Maine, go v/online/tanksmarf)
is a free online service that provides
training and certification for Class A/B operators of underground storage tank
facilities. Congrats to the Maine UST program folks.
                                                                                                          25

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LUSTLine Bulletin 66 • December 2010
  A MESSAGE FROM CAROLYN  HOSKINSON
  Director, USEPA's Office of Underground Storage Tanks

  Move  Over Sisyphus,  Here's a Real

  Challenge: Reducing the National

  LUST  Cleanup  Backlog
     /n Greek mythology, Sisyphus was a king who angered the gods so much that they
     punished him with a difficult and never-ending task. He was made to roll a huge
     rock up a steep hill, but before he could reach the top of the hill, the rock would
  always roll back down, forcing him to begin again. At times, cleaning up  the nation's LUST cleanup backlog seems like a
  Sisyphean task. We continually clean up sites, but the pace of cleanups has slowed, some sites remain open for decades,
  some are not addressed, and all the while new releases add to the workload. There doesn't seem to be an end in sight.
  A Unique Analysis of the Cleanup Backlog
  As of March 2010, more than 491,000 releases from USTs
  had occurred nationwide. The states (with a few done by EPA
  in Indian Country) have made tremendous progress address-
  ing these releases by cleaning up 395,000 (80%) of them.
  This achievement represents an enormous amount of work
  and resources. However, a national backlog of over 96,000
  releases remains, and the annual number of cleanups com-
  pleted nationally has declined steadily since FY 2000. To
  understand the makeup of the backlog of releases and why
  the pace of cleanups is slowing, EPA under-
  took a two-phase data-driven analysis of
  the backlog. Phase 1  of the study uti-
  lized summary data from 45 states
  to determine that 60 percent of
  the backlog was concentrated
  in ten states, that  many
  releases in the backlog
  were old, and that there
  were more groundwa-
  ter than  soil-only sites,
  although many soil-only
  sites remain in the back-
  log.
      In  Phase 2, EPA
  invited  14  states  to
  participate in a more in-
  depth  analysis of their
  LUST  backlogs. We
  were interested in iso-
  lating several attributes of the sites in the  backlog
  (e.g., age, media affected,  prioritization) and looking closer
  at how state cleanup programs functioned. EPA selected
  those 14 states because they are responsible for approxi-
  mately 67 percent of the national  LUST cleanup backlog and
  provide participants from all  ten  EPA Regions.  EPA worked
  with the states to ensure it used the correct data elements
  for analysis, and the states provided  EPA with the  data from
  their LUST cleanup programs.
      By the end  of FY 2009, the cleanup  programs in the
  participating states had closed 71 percent of their cumula-
tive releases but had over 71,000 releases remaining in their
cleanup  backlogs. EPA was able to identify patterns and
trends within the state backlogs that could provide potential
opportunities to reduce the state and national cleanup back-
logs and improve cleanup progress. The  report on  Phase 2
will consist of  14 individual state reports and one  national
summary report. EPA will use the results  of the study to set
the groundwork for discussions with states and tribes and
other stakeholders to develop targeted backlog reduction
strategies.

                         Some  Disconcerting
                         Findings
                         Many of the states'  open
                         releases looked at in Phase
                         2 are very old and still in
                         the early stages of cleanup.
                         Over 50,000  of the releases
                         are ten  years old or  older,
                         and over half of the  releases
                         did  not have a completed
                         site assessment.
                              Many  factors affect  the
                         pace of cleaning up releases,
                        including  funding  availabil-
                     ity  and mechanisms,  statutory
                 requirements, and program structure.
              For example, the current backlog  is likely
           composed of difficult-to-remediate  sites. Data
         indicate that the majority of releases in the back-
     log contaminate  groundwater resources. In  general,
remediating groundwater contamination is more techni-
cally complex,  longer-term, and  more expensive than  reme-
diating soil  contamination. Therefore, larger numbers of
releases  affecting groundwater could be a major reason for
the persistence of the LUST cleanup backlog.
    In addition to the prevalence  of groundwater contami-
nation, the states lacked the resources to fully address all
of these  expensive cleanups in the near term.  EPA is  aware
that state cleanup programs face obstacles to reducing
their backlogs  and that the recent economic downturn has
also had  a tremendous  impact on the states' ability  to make
26

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                                                                             December 2010 • LUSTLine Bulletin 66
  MESSAGE FROM CAROLYN HOSKINSON continued from page 26
  progress on cleanups. State cleanup funds and staff are
  often stretched thin and cleanup costs are increasing. Fur-
  thermore, many cleanups have uncertain financing.
      Is all the low-hanging fruit already picked? Our data
  say, No! But, many of the low-hanging fruit are low-pri-
  ority fruit, and we're  not picking those. State  programs
  use various strategies to address limited resources, such
  as prioritizing releases to focus on the worst sites first.
  These practices have  positive benefits: they address the
  highest risks to human health and the environment and
  protect state environmental resources. However, they also
  can contribute to the  backlog, especially where statutory
  requirements prevent some state programs from complet-
  ing easy, lower-priority closures. Consequently, there are
  many sites in the  backlog that are very old, low priority,
  and will likely remain  unaddressed for many more years
  to come.

  Opportunities to  Reduce the Backlog
  EPA acknowledges that many state programs have initi-
  ated their own backlog reduction strategies. Such efforts
  have included data and file reviews and the use  of tempo-
  rary staff (e.g., interns, contractors) to close more releases.
  Other strategies being implemented include using multi-site
  agreements to encourage responsible party activity, utilizing
  pay-for-performance and other incentives for contractors
                  to reach closure, and referring releases to brownfields pro-
                  grams or other programs like voluntary cleanup programs.
                  EPA wants to highlight these efforts, encourage sharing
                  best practices, and continue to build on states' successes.
                     The Phase 2 report analyzes and presents additional
                  factors related to backlog  releases. Throughout the national
                  study, EPA identifies potential opportunities for improved
                  backlog reduction. The opportunities presented are related
                  to three main categories: accelerating corrective action,
                  pursuing targeted initiatives, and improving program imple-
                  mentation. These opportunities are not intended as spe-
                  cific recommendations. They are meant to open dialogue
                  with the states and other stakeholders on all opportunities
                  to reduce the national cleanup backlog and to serve as the
                  basis for the backlog reduction strategies that EPA intends
                  to develop jointly with the states and tribes.
                     Next steps for EPA include working with the states
                  and tribes to identify and begin to implement backlog
                  reduction strategies, explore further questions about the
                  existing backlog, examine funding issues for LUST clean-
                  ups, look at cleanup goals and milestones, and support
                  the states and tribes in improving LUST program manage-
                  ment. Our role as Sisyphus is more illusion than reality,
                  and by retooling our approaches we can reach the top of
                  the hill. Our work is important to the nation's health and
                  safety, and we must find ways to improve our efforts. •
Investigating Petroleum  UST-Equipment
Problems  and Releases (ASTM  E2733-10)
by Thomas Schruben

    Since  the 1980s, significant
    strides have been made in pre-
    venting releases. By all reports,
the frequency of releases is down,
and the size of releases is typically
smaller than the bad old days of
USTs. But releases still happen, even
in systems that are in full compli-
ance with current regulations. In
fact, when viewed as a fraction of the
active tank population, the rate of
release discovery is now only about
half the rate in the 90s (Figure 1).
    One can argue  that the current
rate of  releases is actually much
lower than that indicated by this
graph, because this  statistic includes
new discoveries of  old releases and
only a fraction of these discoveries
are from new failures. While  there
is probably some truth in this  argu-
ment, it brings  me to the point of
this article—we don't really know
                     4.5%

enough to make
definitive state-
ments about the
rates of releases
or the sources and
causes of releases.
    Congress
tucked  a  pro-
vision  into the
Energy Policy Act
of 2005 that tasked
USEPA with gath-
ering data on the
sources and causes
of  releases, but   	
by all accounts,
the data gathered
so far does not provide the insight
needed to focus prevention efforts on
the weak links in UST systems in the
ground today.
    Carol Eighmey Executive Direc-
tor of the Petroleum Storage Tank
      1990
1995
2000
2005
2010
FIGURE 1. New-release reports nationally as a % of number of active
tanks. Data from 1990 through 2010 EPA 0US7"Semiannual Report of
UST Performance Measures.
                 Insurance Fund, compiled Annual
                 "Source and Cause Reports" from
                 47 state UST programs. (For more
                 information, contact Carol Eighmey
                 at pstif@sprintmail.com.)  Eighmey
                 has concluded that the data pres-
                                • continued on page 28

                                              27

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LUSTLine Bulletin 66 • December 2010
 lASTME2733-10^om
27
ent "a largely meaningless picture in
which the vast majority of releases
are catalogued  with 'other'  or
'unknown' as the source or cause of
the release, providing little insight
into what  equipment is failing or
which regulations need strengthen-
ing or increased enforcement."

And So, a Standard Guide
Gathering data that can be analyzed
for sources and  causes of failure
requires investigation and unifor-
mity—some kind of standardized
data-gathering method. Creating this
kind of  standard sounded like a job
for the American Society of Testing
Materials (ASTM), so Dennis Rounds,
Director of Risk Management for
South Dakota and Past Chair  of the
E50.04 Subcommittee on Environ-
mental Corrective Action, asked me
and the ASTM E50.04 Subcommittee
to develop what has now been pub-
lished as the ASTM E2733-10 Standard
Guide for Investigation of Equipment
Problems and Releases for Petroleum
Underground Storage Tank Systems.
   Several years ago Dennis con-
ducted  an UST autopsy study for
South Dakota's Petroleum Release
Compensation Fund. The informa-
tion from  that study has been very
useful to  the UST  community in
South Dakota. Dennis would like to
make it easier for states to collect this
type of information routinely during
tank closures. He believes that states
would benefit from greater  detail
and uniformity in sources and causes
of release data. Both Dennis and I
believe that this data can be collected
by inspectors, tank removal contrac-
tors, and tank maintenance contrac-
tors with little additional expense.
   E2733  is intended to assist in the
development  of protocols for  the
investigation of a malfunction or fail-
ure of storage tank systems and the
implementation of  said protocols.
The guide outlines steps that may be
necessary, including but not limited
to: initial evaluation of the UST sys-
tem to determine the malfunction(s);
preparation of samples of failed
equipment for laboratory analysis;
and documentation of the investiga-
tion.
   The guide provides a series of
investigation options the user may
employ to design failure investiga-

28
tion protocols. It describes common
investigation techniques in the order
in which they might be employed
in an investigation. In other words,
it puts some meat on the bones of
collecting data on the  sources and
causes of releases.
    A user may elect to utilize this
guide  for a  number  of  reasons,
including but not limited to:
•  Differentiating new releases from
   new discovery of old releases
•  Establishing malfunction and fail-
   ure rates of various storage tank
   equipment components
•  Determining expected  life  spans
   of various storage tank equipment
   components
•  Identifying opportunities  for
   improving the performance and
   reliability of storage tank equip-
   ment
•  Focusing inspection  and mainte-
   nance efforts on portions of the
   tank system most prone to mal-
   function and failure
•  Identifying components of  the
   storage tank system that require
   more frequent maintenance
•  Reducing remediation and equip-
   ment replacement costs
•  Preventing petroleum releases
•  Identifying conditions that may
   cause or contribute  to the dete-
   rioration or cause the malfunction
   and failure of various components
   of the UST system
•  Complying  with environmen-
   tal regulations  that require  the
   investigation of release-detection
   alarms and the source of releases.
    The guide may be used to  estab-
lish a framework that pulls together
the common approaches to UST sys-
tem investigation and allows users
to establish an investigation protocol
to meet their specific requirements.
Specific user requirements will vary
depending on the purposes of the
data collection and the decisions that
the investigation is intended to sup-
port.
    While  the guide focuses on iden-
tifying and documenting UST system
equipment problems and preserv-
ing problem equipment and does not
provide guidance on establishing root
causes of equipment malfunction or
failure, it does provide the first, nec-
essary steps in a root-causes inves-
tigation. Identifying the root causes
of equipment malfunction or failure
may require further expert analysis
of the data and equipment collected
during the failure investigation.
    The guide includes informa-
tion on methods of investigation,
documentation,  taking samples of
problem  equipment, preserving
equipment samples, chain of cus-
tody, storage, shipping, working
with equipment manufacturers, and
notifying regulators and listing labo-
ratories. It provides techniques for
documenting problems  while the
tank system is operating, while it is
being removed, and after the equip-
ment has been removed.
    Working with equipment manu-
facturers is particularly  important
because they need to know about
problems in the  field if they are to
improve their equipment and pro-
vide effective instructions to the
installers, maintenance contractors,
and owners of tank systems. Simi-
larly, notifying listing laboratories
like UL provides valuable real-life
information they can use to improve
the  testing and listing procedures for
the  equipment they list.

Implementation Pilot Project?
As  wonderful and useful you may
think this guide is, publishing a
guide is only the  first step to a better
world. As is oft-repeated in the pages
of LUSTLine, implementation is the
key. To that end, Dennis Rounds
and I would be happy to  work with
states where there is interest in doing
a pilot project on incorporating this
guide, first, into their inspector train-
ing program and eventually into
their installer or tank-removal train-
ing programs. We feel that a pilot
project would help refine the  guide
and bring in the  knowledge needed
to start compiling useful statistics.
If you are interested contact Dennis
Rounds (dennis.rounds@state.sd.us)
or me. If you would like a  copy of
the standard, it can be purchased
at ASTM.org or  contact Dan Smith
(dsmith@astm.org) for more  infor-
mation on obtaining this standard
for regulators. •

    Tom Schruben  is an independent
    environmental risk-management
 consultant and UST-equipment failure
    investigator. He can be reached at
     environmentalguy@aol.com.

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                                                                          December 2010 • LUSTLine Bulletin 66
Class  C  Operator  Saves the Day When Dogs
Drive  Van into  Dispenser
by Ben Thomas


      As a trainer you want to think
      all your hard work pays off
      and that the folks you train
are  actually putting into practice
what they've  learned. And  some-
times you get a small reward  as a
reminder that what you  are doing
matters. This story is about such a
reminder.
    When we used to  do more
classes live  and in person, I would
sometimes get an operator who had
to take an emergency call on his or
her  cell  phone and step out of the
room to respond to an alarm or spill.
And because the operator was  in a
classroom and off-site—usually in
some city halfway across the state—
response was limited to delegating
action to an on-site coworker.
    With Web training, people can
be attending from anywhere. When
we  do Class A/B webinars, people
often take the  class in an  office  and
sometimes even in the back room of
a C-store.
    In December 2009, I received
an email at lunch  break during an
online Class A/B  Operator class I
was conducting:
    "Sorry I had to scramble out of
  class today. A customer parked his
  van while he was having lunch in my
  deli, his "dogs" jumped on  the steer-
  ing wheel/dash board and put it into
  gear! [The engine was on.] Rolled
  into the pump, smashed it.  Fuel
  started flowing. THANK GOOD-
  NESS for my responsible certified
  "C" Operators!!!! They did every-
  thing right. One person shut off the
  emerg. switch and breakers while the
  other one contained the flow of the
  spill with the socks, pads, etc. and
  the 3rd one called me! WHEW! Fire
  dept. wasn't necessary.
    I will be in class tomorrow while
  all the "certified" workers are trying
  to get my business running again."

    When I emailed back for details,
the  operator  told  me they  had
certified their Class C operators
two months ago, and all the store
employees  had attended a  safety
                                         Lessons Learned:
                                         Q Even with training, acci-
                                           dents can and do happen,
                                           sometimes where you least
                                           expect it.
                                         Q Training compliance can
                                           be measured by certificates
                                           or response actions. We
                                           like the latter.
                                         Q Training can result in a sig-
                                           nificant savings of time,
                                           money, and petroleum.
                                         Q Using real, live incidents
                                           as case studies  can be a
                                           very informative learning
                                           tool.
                                         Q When you're at a C-store,
                                           don't leave the engine on
                                           when you go inside! •
Damaged dispenser.
meeting a couple of weeks
prior. When I asked what hap-
pened  at the dispenser she
replied:
    "The shear valve did not
shear. The impact of the van
crashing into the dispenser
broke the connection between
the filter  housing and the
delivery piping, even break-
ing off the bolts! The electri-
cal conduit got displaced and
opened also. I did take several
pictures. I will try and down-
load and send them to you by
class tomorrow."
    The second day of class,
the operator  very generously
allowed me to share the pho-
tos. The cool thing about the
webinar as a learning plat-
form is that we were able to
look at the pictures, discuss   	
what happened, sleuth out the
causes, and have an interactive study
case—all in  nearly real time. The
students really appreciated using
the incident as a learning exercise to
make the training material more rel-
evant and meaningful.
The shear that didn't shear.
        Ben Thomas is an online trainer for
        class A, B, and C operators. A former
        LIST regulator in Alaska, he has been
        training operators since 2004. He can
        be reached at ben@USTtraining.com.
                                                                                                29

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LUSTLine Bulletin 66 • December 2010
 from Robert N. Renkes, Executive Vice President, Petroleum Equipment Institute (PEI)

  PEI Revises RP100  UST  Installation  Document
       The 2011 edition of the Petroleum Equipment
       Institute's (PEIs) Recommended Practices for Instal-
       lation of Underground Liquid Storage Systems (PEI/
  RP100) is now available. This eighth edition of RP100
  supersedes the previous recommended practices of the
  same name that were published in 2005. PEI revises
  RP100, when warranted, to ensure that users of its doc-
  uments receive the latest guidance on the proper meth-
  ods and techniques for installing underground storage
  tank (UST) systems.
      PEI's Tank Installation Committee, which includes
  installers and federal  and state UST regulators,
  reviewed over 70 suggestions submitted by various
  individuals and groups to revise the previous edition
  of PEI/RP100. The committee accepted more than 50
  percent of these comments in some manner. I won't
  go through all of the changes here for several reasons.
  First, we don't have enough space in LUSTLine to list
  them all. And second, I'm afraid it would put all but
  the most avid tank installer/regulator to sleep. Having
  said that, however, several of the changes are worth
  noting and will provide you with a sense of the kinds
  of issues the committee addressed and how they dealt
  with them.
  • Recognizing that ballasting underground tanks with
    water may promote problems with microbial con-
    tamination that may lead to subsequent fuel-qual-
    ity issues, the document now recommends that the
    installation of submersible pump motors be post-
    poned until after the water ballast has been com-
    pletely removed (Section 5.3).
  • The committee confirmed that the UST has to be
    tight for flapper valves to be used as overfill pre-
    vention by requiring that all risers above the flow
    shut-off device be properly sealed to prevent prod-
    uct from being discharged when the overfill shut-off
    device closes (Section 7.3.2).
  • The warning that prohibited vent-restriction devices
    on emergency-generator or heating-oil supply tanks
    has been removed (Section 7.3.3) because it was con-
    sidered to be redundant with another warning in
    the same section.
  • Language reflecting the secondary  containment pro-
    visions of The Energy Act of 2005 was incorporated
    in the secondary-containment chapter (Section 8).
  • A new section for transition sumps was added.
    New Section 8.6 now states: "Transition sumps may
    be required for reasons of extending existing pip-
    ing systems, extending from underground piping
    to aboveground apparatus, or creating branches in
  piping. Transition sumps have similar requirements
  as other sumps, but, additionally, should always be
  continuously monitored and installed in conjunc-
  tion with a raised concrete apron not less than 24
  inches all around the grade opening for durability
  reasons."
• A new warning was added to the groundwater
  monitoring section, admonishing installers never to
  use fill caps or similar-appearing covers for observa-
  tion-well service (Section 9.2.2).
• The committee noted that many truck stops and
  other large facilities have been installed with line
  leak detection that does not function properly. A
  new warning has been added to the automatic line
  leak detection section, explaining that mechanical
  line leak detectors may be insufficient to detect leaks
  quickly in high-throughput systems or systems with
  submersible pumps operating in tandem. The warn-
  ing goes on to suggest that additional means of leak
  detection may be required (Section 9.3.1).
• If a piping manufacturer permits a shallower piping
  installation depth than recommended  in RP/100,
  the document will now allow those shallower
  depths, provided the installation is thoroughly com-
  pliant with the manufacturer's specifications for
  configuration and quality (Section 10.4).
• RP/100 has long maintained, as a general rule, that
  product piping maintain a minimum slope of 1/8
  inch per foot toward the tank, a dispenser sump, or
  a collection sump. The committee elaborated on that
  statement by  adding the following language to the
  third paragraph of Section 10.4: "In pressure sys-
  tems, slope may not be necessary on supply lines.
  Rather, communication between the  interstitial
  space of secondarily contained pressure supply lines
  and collection sumps should be maintained so that
  released product can enter a sump and be visually
  observed or detected by sensors. For safe suction-
  piping configurations, the entire piping run must
  slope down to the tank, allowing  product to drain
  safely if air should enter."
   The committee also made changes in the sections
of the recommended practices dealing with piping
trenches (tracer tape), threaded joints, flexible con-
nectors, fuel compatibility, and vent piping. New sec-
tions on shear valves and manhole identification were
added. All the drawings were updated.
   The 2011 PEI/RP100 is copyrighted and may not
be photocopied or otherwise reproduced. Order copies
online at iviviv.pei.org/rplOO. •
30

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                                                                           December 2010 • LUSTLine Bulletin 66
FAQs from the  NWGLDE
...All you ever wanted to know about leak detection, but were afraid to ask.
Unsupported  Leak  Detection  Methods
In this LUSTLine FAQs from the National Work Group on Leak Detection Evaluations (NWGLDE), we discuss leak detection meth-
ods that are no longer supported by the company that markets them. Note: The views expressed in this column represent those of
the work group and not necessarily those of any implementing agency.

                                                      The NWGLDE depends on the company that mar-
                                                      kets a leak detection method to notify us of any
                                                      changes. As we are made  aware of corporate
                                                      changes (e.g., companies being acquired by other
                                                      companies, ceasing operation), this information is
                                                      added to the NWGLDE list. However, this informa-
                                                      tion will not always be on the listings, because we
                                                      don't always receive this information. Even if we do
                                                      receive the information, we may not be able to ver-
                                                      ify its accuracy.

                                                      Please be aware that even though a NWGLDE leak
                                                      detection method listing indicates that a company
                                                      is out of business, or that the equipment is no longer
                                                      supported by the manufacturer, the method still has
                                                      the potential to perform well without further support.
                                                      Theoretically these unsupported methods could func-
                                                      tion indefinitely. However, as technology advances,
                                                      some of these methods may encounter compatibility
                                                      issues (new computer operating systems that will not
                                                      run certain software, unavailability of replacement
                                                      parts). In these scenarios, even though a leak detection
                                                      method is still listed by the NWGLDE, the method
                                                      will become obsolete, and another leak detection
                                                      method will need to be used. •
    According to the NWGLDE website, [a certain com-
    pany] is out of business. Given this circumstance, is
    this method still approved by the NWGLDE?

A. Before answering this question, we need to make it
    clear that the NWGLDE list is not a list of "approved"
    leak detection methods. Please review the disclaimer
    on our website at http://iviviv.nivglde.org/disclaimer.
    html. The NWGLDE list is a compilation of meth-
    ods that meet the criteria for being listed on our list;
    namely, a successfully completed third-party evalua-
    tion that is properly performed in accordance with a
    protocol that has been found to be acceptable to the
    NWGLDE.

    Now, the answer to the question: Once a leak detec-
    tion method has met the criteria for being listed,
    it remains on the list, even if the company is out of
    business or the company no longer provides support
    for the method. We do this because those who have
    purchased the leak detection  method may still be
    using that method. To remove such a method from
    the NWGLDE list could create problems in states
    where the method is still in use, and only leak detec-
    tion methods that are listed by the NWGLDE are
    allowed.

    If a state has concerns about tank owners using listed
    leak detection methods that may no longer have sup-
    port from the manufacturer, we suggest that the state
    develop a policy or regulation that would preclude
    tank owners from using such methods. (Please note:
    the NWGLDE does not get involved with the devel-
    opment of implementing agency policy or regula-
    tion.)
                                                   About the NWGLDE
                                                   The NWGLDE is an independent work group comprising ten members,
                                                   including nine state and one USEPA member. This column provides
                                                   answers to frequently asked questions (FAQs) the NWGLDE receives
                                                   from regulators and people in the industry on leak detection. If you have
                                                   questions for the group, please contact them at questions@nwglde.org.
          L«U«S«T«LINIE  Subscription Form
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  J One-year subscription: $18.00

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                                                                                                   31

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New England Interstate Water
Pollution Control Commission
116 John Street
Lowell, MA 01852-1124
      Ellis and Frye Receive LUST Poster Session  Lifetime Achievement
                       Awards at the  National Tanks Conference
       The LUST Poster Session  Lifetime
       Achievement Award was presented
       this year to Pat Ellis  of Delaware,
  DNREC, and Ellen Frye, Editor of LUSTLine.
  Pat was recognized for her many years of
  dedication, leadership, and significant con-
  tributions to the science of site assessment,
  risk evaluation, and cleanup for LUST sites.
  Ellen was  recognized for her dedication
  and tireless efforts to ensure that the lat-
  est information on operating and cleaning
  up underground storage tank sites is dis-
  seminated and documented in LUSTLine,
  the "bible" of the UST/LUST program. The
  award  was presented from their friends
  and colleagues with many thanks for years
  of dedication and significant contributions.
  Previous award recipients include John
  Wilson, USEPA Kerr  Lab, Bruce Bauman,
  American Petroleum  Institute, and Robin
  Davis, Utah DEQ. •
Pat Ellis and Ellen Frye receive the 2010 LUST Poster Session Lifetime Achievement
Award. From left to right: Pat Ellis, DE, DNREC, John Wilson, USEPA ORD, 2007 award
recipient, Ellen Frye, LUSTLine Editor, Robin Davis, Utah DEQ, 2009 award recipient,
and Bruce Bauman, API, 2008 award recipient.

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